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.
Bloomberg Tax Management Portfolios
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.