Marty Collins is a Partner in PricewaterhouseCoopers LLP Washington National Tax Services Office.
Marty practice covers a wide-range of cross-border tax issues, including analyzing developments and identifying planning opportunities arising from new tax legislation, regulations and treaties.
Marty specializes in advising clients on structuring tax-efficient acquisition and disposition structures, cross-border reorganizations including section 7874 (inversion) considerations, inbound financing structures, cross-border joint ventures, and principal/entrepreneur structures. Marty's practice includes developing and analyzing strategies for tax-efficient IP, financing and holding-company structures, including strategies for the redeployment of foreign earnings. Marty regularly advises clients on the U.S. anti-deferral (e.g., Subpart F income), overall foreign loss, and foreign tax credit rules and regulations.
Marty frequently speaks and writes on a broad range of international tax issues.
Marty joined PricewaterhouseCoopers in 1995 in Baltimore; transferred to Washington National Tax Services from 1998 to 2003; transferred to Chicago from 2003 to 2005; and then rejoined in March 2008 from McDermott Will & Emery where he was a partner in that firm’s tax practice from 2005-2008.
Education:
J.D., University of Baltimore
MST (Taxation), University of Baltimore
B.A., The Catholic University of America
Tax Management Portfolios™
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Indirect Foreign Tax Credits (Portfolio 6040)
This Portfolio contains a detailed analysis of the indirect foreign tax credit system as in effect both before the enactment of the Tax Cuts and Jobs Act (TCJA) (Pub. L. No. 115-97) in 2017. This Portfolio is divided into eleven parts.