Dirk Suringa is a Partner in the Washington, D.C. law firm of Covington & Burling LLP, practicing in the areas of international tax planning and controversies. Mr. Suringa advises clients regarding the Federal income tax aspects of domestic and international transactions and structures and represents clients before the Internal Revenue Service, the Treasury Department, and in the Federal courts.
Mr. Suringa served as Attorney-Advisor in the Department of the Treasury's Office of International Tax Counsel from 2000 to 2003. From 1996 to 1997, Mr. Suringa clerked for the Honorable Gerald B. Tjoflat, Chief Judge of the United States Court of Appeals for the Eleventh Circuit.
He is the author of numerous articles on international tax matters, including the Tax Management Portfolio on the Foreign Tax Credit Limitation, and is a member of the Executive Committee of the US Branch of the International Fiscal Association.
Education:
J.D., Harvard Law School (1996) magna cum laude
B.A., Princeton University (1992)
Tax Management Portfolios™
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The Foreign Tax Credit Limitation Under Section 904 (Portfolio 6060)
This Tax Management Portfolio discusses one part of the U.S. foreign tax credit mechanism—the foreign tax credit limitation under §904. The basic purpose of the limitation is to ensure that the United States does not allow foreign taxes to be used as a credit against U.S. tax on any U.S.-source income.