Allen Stenger is a Principal based in Washington, D.C., in Ernst & Young LLPs National Tax Department (International Tax and Transaction Services). Previously, Mr. Stenger served as a law clerk to Judge James S. Halpern of the United States Tax Court and was a tax associate at Skadden, Arps, Slate, Meagher & Flom LLP.
Allen is a frequent speaker and writer on a variety of international tax topics. He received a B.A., summa cum laude, from the University of Notre Dame; a J.D., cum laude, from Harvard Law School; and an LL.M. in Taxation (with distinction) from Georgetown University Law Center.
Tax Management Portfolios™
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Participation Exemption Regime Under Section 245A (Portfolio 6130)
Bloomberg Tax Portfolio, No. 6130, Participation Exemption Regime Under Section 245A, discusses the rules for a domestic corporation claiming a deduction under §245A of the Code with respect to certain dividends received from a 10%-owned foreign subsidiary.