William M. Funk is a tax attorney with extensive experience in tax planning and dispute work. His practice focuses on representing funds, businesses, individuals, and non-profit organizations. He started his practice in 2009 after working for large New York firms on matters including hedge fund offerings, corporate transactions, and cross-border investments of high-profile private equity funds.
Representative matters include:
- Advising foreign businesses on minimizing and managing their U.S. tax exposures, including choices of U.S. business entities, tax treaty utilization, compensation for services and use of intellectual property, compliance requirements and other issues.
- Advising U.S. businesses and investors on foreign tax credit utilization, use of GILTI and FDII deductions, taxation of controlled foreign corporations and PFICs, qualified dividend rules, compliance with foreign income and asset reporting rules and other issues.
- Advising funds on structuring domestic, inbound and outbound investments, including issues such as entity election, drafting offering documents, tax treaty planning and compliance with withholding and reporting rules.
- Organizing and obtaining tax exemptions for many nonprofits including public charities and private foundations, advising nonprofits on all phases of their life-cycle, from formation to operations (including domestic and international) to dissolution.
- Representation of individuals before the Internal Revenue Service and the New York State Department of Taxation and Finance for relief from garnishment of wages and levies on bank accounts.
He has also been published in leading tax publications on issues ranging from taxation of real estate developments to international tax policy.