Allen joined the firm's Corporate and Tax group in 2012 after practicing for many years with a prominent tax law firm in Dallas, Texas. His practice focuses on tax planning, tax controversy and litigation, and international tax compliance. Over the years, Allen's practice has become both national and international in scope, and has expanded beyond the tax arena into related areas. For example, he also helps clients comply with increasingly important anti-bribery and anti-corruption laws such as the Foreign Corrupt Practices Act (FCPA).
A consistent willingness to learn new areas of the law allowed Allen to develop an eclectic tax planning background that includes experience in individual, corporate, pass-through, and international tax issues. He represents a broad range of tax planning clients including family-owned entities and estates, publicly-held institutions, and nonprofits in matters such as entity formation, mergers and acquisitions, corporate restructuring, property distributions, “Subpart F” planning and profit repatriation, and many other related issues.
In response to ever increasing client needs, Allen developed extensive experience in tax controversies and litigation related to individual, business, international, and estate taxes. He now dedicates about half of his professional time to tax controversy work, which causes him to interact with the Internal Revenue Service and similar state agencies on a daily basis. Allen’s efforts on this front include audit representation, IRS appeals negotiations, collections matters, penalty abatements (domestic and international), and Tax Court litigation, to name a few.
His tax controversy experience includes an expertise in offshore account and foreign entity compliance. He has represented dozens of U.S. citizens and residents, dual citizens and their families, and related entities in properly reporting their offshore holdings and in reconciling previous compliance missteps, failures, and deficiencies. Allen’s offshore compliance practice also includes expertise and experience in the IRS’s Offshore Voluntary Disclosure Initiatives for persons with unreported foreign entities and bank accounts.
In addition to advising clients on tax matters, Allen helps clients comply with anti-corruption and anti-bribery law such as the FCPA and the UK Bribery Act. Many U.S. companies have seen increased pressure to export their products outside of the U.S. to maintain revenue and competitiveness. When this pressure is coupled with an ever-increasing focus on FCPA enforcement at the Securities and Exchange Commission and the Department of Justice – evidenced by many recent high-profile prosecutions – the need for an effective company-wide anti-corruption policy becomes clear. With this in mind, Allen helps businesses tailor their policy to their particular products and services while also focusing on the nature and extent of their international sales efforts. This includes drafting and developing corporate anti-corruption policies and third party due diligence documents, and conducting training programs for international sales forces.