David G. Noren is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Washington, D.C. office. He focuses his practice on international tax planning for multinational companies. David’s work in this area covers a wide range of both “outbound” and “inbound” issues, with particular focus on the subpart F anti-deferral rules, the application of bilateral income tax treaties, and the treatment of cross-border flows of services and intellectual property rights under transfer pricing and other rules. He has been ranked as a leading international tax lawyer by The Legal 500 United States.
Prior to joining the Firm, David served for nearly five years as legislation counsel to the Joint Committee on Taxation in the U.S. Congress, where he advised the House Ways & Means Committee, the Senate Finance Committee, and other members of Congress on proposed international tax legislation. He played a major role in the development of several international tax bills, including those culminating in the American Jobs Creation Act of 2004. He also advised the Senate Foreign Relations Committee on the review and ratification of several tax treaties and protocols, carried out the international tax aspects of special investigations and studies requested by members of Congress, and assisted in the Joint Committee staff's review of large tax refunds in the international area. Prior to working in Congress, David taught in the tax program at the New York University School of Law and practiced tax law in the Chicago office of another prominent law firm.
David is a frequent writer and speaker on international tax issues. His articles have appeared in the BNA Tax Management International Journal, the IBFD International Transfer Pricing Journal, the Tax Law Review, Taxes--The Tax Magazine, and Tax Notes, and he is a co-author of the BNA Tax Management Portfolios on CFCs--General Overview and CFCs—Foreign Personal Holding Company Income. David has spoken at conferences and seminars hosted by the American Bar Association, BNA Tax Management Advisory Board, District of Columbia Bar, George Washington University, International Fiscal Association, Tax Executives Institute, Tax Council Policy Institute and the University of Chicago. David also has testified in Congressional hearings on international tax issues, and he is currently serving as vice chair of the International Tax Committee of the District of Columbia Bar Taxation Section.
J.D., Harvard Law School (1996) magna cum laude
A.B., Stanford University (1993) with distinction
Bloomberg Tax Management Portfolios
This Portfolio describes the rules for the U.S. federal income taxation of shareholders of controlled foreign corporations (CFCs) under Subpart F of the Internal Revenue Code.
This Portfolio provides a analysis of foreign personal holding company income, foreign base company income and "Subpart F income".
This Portfolio focuses on the provisions of §954 other than those pertaining to foreign personal holding company income.