Rod Donnelly is a tax partner at Morgan, Lewis and Bockius, LLP. His practice focuses on the tax aspects of complex international corporate transactions. Representing large multinational corporations, his experience includes transfer pricing, especially with an intangible property component, at both the planning and controversy stages. Rod’s experience also includes Subpart F and foreign tax credits, as well as tax-related aspects of manufacturing supply chain and R&D, at both the planning and controversy levels.
Education:
B.Sc., University of London
M.Eng., Memorial University
Ph.D. (Mathematics), Carleton University
J.D., University of Toronto
Tax Management Portfolios™
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U.S. Income Tax Treaties — Permanent Establishments and Related Business Provisions (Portfolio 6860)
This Bloomberg Tax Portfolio analyzes U.S. income tax treaty provisions that relate to business income associated with permanent establishments, the specialized treatment of real estate, and international shipping and aircraft activities.