Philip Fried is a principal with PwC’s US International Tax Services Financial Services group. His focuses on advising financial service clients on M&A, foreign tax credit, losses and other attribute management, tax-efficient redeployment of funds, and operational restructurings. He has extensive experience in advising investors, investment managers and funds on the structuring of hedge funds, private equity funds, and publicly-traded partnerships. In addition, he speaks on topics such as the use of check-the-box in the international context, Section 367 and Section 304.
He is a member of the New York Bar.
LL.M. in Taxation, New York University School of Law (1997)
J.D., Harvard Law School (1990)
B.A., Stanford University (1987)
Bloomberg Tax Management Portfolios
This portfolio analyzes the U.S. income tax consequences under §956 of the Internal Revenue Code of investment.