Thomas Cryan's arrival at Miller & Chevalier was covered by General Counsel News.
- Advised a large multinational retailer on the development of a comprehensive Chapter 3 and Chapter 4 (FATCA) compliance program, registration of foreign financial institutions within its expanded affiliated group, and the application of FATCA regulations and intergovernmental agreements to entities and retirement plans located in several foreign countries.
- Advised a foreign systemically important financial institution on various issues related to FATCA, including application of the grandfathered obligation rules to various financial products and due diligence obligations.
- Advised a private equity fund on the proper FATCA classification and FATCA compliance obligations of various entities and funds located in multiple jurisdictions around the world.
- Successfully represented an energy company in an audit before IRS appeals asserting over $100 million in information reporting penalties and backup withholding failures related to payments of non-employee compensation and payments to attorneys.
- Advised an aircraft charter company during an IRS audit of the proper Chapter 3 withholding and reporting treatment of foreign employees operating aircraft in international travel between the United States and foreign jurisdictions.
- Developed a remediation plan and advised a large national retailer on compliance with California’s nonresident withholding tax regime including the Withholding Voluntary Compliance Program.