Mr. Kemm’s practice focuses on international tax matters for both domestic and non-U.S. clients. With 30 years of combined practice as a tax lawyer and CPA, Mr. Kemm has vast experience advising clients in structuring international transactions and business operations in a tax efficient manner, and in representing clients before the IRS in international tax disputes.
Mr. Kemm counsels clients on international tax matters related to the organization and reorganization of cross-border business structures, including international joint ventures, mergers, acquisitions and divestitures. In addition, he advises clients on international tax planning matters, such as income tax deferral, foreign tax credit utilization, transfer pricing strategies and maximization of tax treaty benefits, among others. He coordinates global planning and transaction structures by working with an extensive network of lawyers throughout the world.
Mr. Kemm has served as counsel in numerous tax controversy matters at the audit, appeals and litigation levels. He has also represented numerous clients in voluntary disclosures, as well as penalty disputes related to foreign bank account reporting under the Bank Secrecy Act.
Mr. Kemm speaks regularly before various professional organizations and has authored numerous publications on international tax topics. He is licensed as a Certified Public Accountant in the State of Texas, and is admitted to practice before the United States Tax Court, the United States Court of Federal Claims and the United States District Court for the Northern District of Texas.
J.D., Indiana University School of Law (1992) summa cum laude
B.S., University of Missouri – Kansas City (1984)
Bloomberg Tax Management Portfolios
CFCs — Sections 959-965 and 1248 (Portfolio 930)
This Portfolio describes the rules that apply to the repatriation of the earnings and profits of a CFC under Subpart F of the Internal Revenue Code.