Rafic H. Barrage is a partner in Baker & McKenzie’s Tax Practice Group. He has over 14 years of broad international tax planning and controversy experience. Mr. Barrage advises clients on a variety of issues, including restructuring and entity rationalization, IP migration, supply chain planning and principal structures, e-commerce and cloud computing, deferral and repatriation planning, foreign tax credit planning, and pre- and post-acquisition planning. Mr. Barrage is a recognized leader in his field by The Legal 500 (2010 and 2011) (described as one of the “impressive younger partners” and “technically very strong”) and as one of the Tax Controversy Leaders by the International Tax Review (2011 and 2012). Mr Barrage is an Adjunct Professor of Law at Georgetown University Law Center, where he teaches the international tax course, International Business Planning Workshop.
Mr. Barrage regularly advises US corporations operating overseas and foreign corporations and individuals operating and investing in the United States on a broad range of international tax issues. Among other industries, Mr. Barrage’s practice focuses on the software and high-technology, pharmaceutical and life sciences, and the shipping (container and cruise line) industries.
LL.M. Taxation Distinction, Georgetown University Law Center (2000)
LL.M. International & Comparative Law, Georgetown University Law Center (1999) with distinction
J.D. Mercer University, Walter F. George School of Law (1998)
LL.B., London Guildhall University
Bloomberg Tax Management Portfolios
Bloomberg Tax Portfolio, U.S.-to-Foreign Transfer Under Section 367(a), No. 6100, describes in detail the statutory and regulatory rules of §367(a), one of the fundamental international tax provisions that addresses outbound transfers of property, as well as the related reporting provisions of §6038B.
Federal Taxation of Software and Digital Transactions describes the U.S. federal income taxation of software and digital transactions.