Nils Cousin is a Director of International Tax at PricewaterhouseCoopers where he specializes in tax consulting for inbound clients, including tax treaties, inbound structuring, sovereign investment, and section 7874. Prior to joining PWC Mr. Cousin spent four years as an Attorney Advisor to Hon. Joseph Gale, Judge, U.S. Tax Court.
Mr. Cousin is frequently published in Bloomberg BNA publications including Tax Management Memorandum and Tax Management International Journal. Recent articles have included:
- The Current State of FATCA Readiness, Remaining Issues, and the Impetus Toward Global Information Reporting, 55 T.M.M. 135 (April 21, 2014)
- We Ordered Pancakes, Not Waffles - How Section 7874 Guidance Has Delivered Something Other Than What Congress Ordered, 42 T.M.I.J. 319 (June 14, 2013) (co-authored with Mike DiFronzo, Marty Collins, and Kirby Huelsebusch)
- The Evolving FATCA Guidance, 42 T.M.I.J. 183 (April 12, 2013) (co-authored with Steve Nauheim)
- An Order of Rice Cakes: the Impact of Public Offerings and Private Placements on Section 7874: an Analysis of the 2014 Temporary and Proposed Regulations, 43 T.M.I.J. 315 (June 13, 2014) (co-authored with Mike DiFronzo and Marty Collins)
LL.M., Taxation, Georgetown University Law Center (2007)
J.D., Law, University of San Diego School of Law (2006) cum laude
B.A., Mathematics, Political Science, Emory University (2000)
Bloomberg Tax Management Portfolios
This Portfolio discusses the reporting and withholding requirements of chapter 4 (§1471–§1474) of the Internal Revenue Code.