- U.S. tax counsel to one of the largest foreign multinational financial services groups.
- Advised a major European banking association on U.S. tax regulations affecting foreign member banks.
- Representing a number of significant European multinational companies in connection with their U.S. structurings, restructurings and operations in the United States.
- Initiated a number of Competent Authority tax proceedings with respect to the mitigation of double tax on dual country residents.
- Phone: +1 212 210 9425
- Email: edward.tanenbaum@alston.com
Edward Tanenbaum is senior counsel in Alston & Bird's Federal & International Tax Group and a member of its Global Services & Strategies Committee. Edward's practice consists primarily of planning and structuring tax-efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals, including through the use of double tax treaties. He has also advised on the various U.S. anti-deferral tax regimes in connection with the offshore investments of U.S. multinationals, citizens and resident aliens; counseled on corporate inversions; and advised on numerous international and cross-border joint ventures, acquisitions, restructurings and reorganizations. Edward focuses his overseas practice primarily on the D-A-CH region (Germany, Austria and Switzerland) and the Benelux countries and is a member of Alston & Bird's German Practice Team (CV auf Deutsch).
Edward has made significant contributions to the drafting of the U.S. tax regulations affecting withholding taxes on payments of U.S. income to nonresident aliens and foreign corporations and has been instrumental in the creation of the IRS “Qualified Intermediary” regime applicable to foreign financial institutions. He has counseled extensively on the Foreign Account Tax Compliance Act (FATCA) regime and also advises regularly on international cross-border tax enforcement matters.
Edward is a frequent speaker at various tax conferences and regularly publishes articles on international tax topics. He is a Director of the International Tax Institute as well as a member of the Steering Committee of the USA Branch of the International Fiscal Association.
Edward has been consistently recognized by Chambers USA, International Tax Review, The Best Lawyers in America®, and Super Lawyers. His work for German clients who need U.S. tax advice has earned him designation as a “Foreign Expert” by Chambers Global.
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Press Release February 13, 2025Alston & Bird Increases Rankings in Chambers Global 2025Alston & Bird has been recognized in the 2025 edition of Chambers Global, with 12 practices and 24 lawyers cited for excellence.Press Release February 13, 2025Alston & Bird Increases Rankings in Chambers Global 2025Alston & Bird has been recognized in the 2025 edition of Chambers Global, with 12 practices and 24 lawyers cited for excellence.
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General Publications November 2024“U.S. Supreme Court Holding Adds Complexity to Estate Planning,” Employee Benefit Plan Review, November 2024.This article discusses the impact of the Supreme Court decision in Connelly v. United States on taxpayers.General Publications November 2024“U.S. Supreme Court Holding Adds Complexity to Estate Planning,” Employee Benefit Plan Review, November 2024.This article discusses the impact of the Supreme Court decision in Connelly v. United States on taxpayers.
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Advisories July 31, 2024Federal Tax Advisory: Supreme Court Holding Adds Complexity to Estate PlanningKeeping it in the family just got more complicated. Our Tax Group studies a Supreme Court decision that left a family with an unexpected estate tax liability related to a share redemption agreement.Advisories July 31, 2024Federal Tax Advisory: Supreme Court Holding Adds Complexity to Estate PlanningKeeping it in the family just got more complicated. Our Tax Group studies a Supreme Court decision that left a family with an unexpected estate tax liability related to a share redemption agreement.
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Press Release June 6, 2024Alston & Bird Increases Practices and Attorneys Recognized in Chambers USA 2024Alston & Bird has received significant recognition in the 2024 edition of Chambers USA: America’s Leading Lawyers for Business, with 73 practice rankings and 153 leading lawyer listings.Press Release June 6, 2024Alston & Bird Increases Practices and Attorneys Recognized in Chambers USA 2024Alston & Bird has received significant recognition in the 2024 edition of Chambers USA: America’s Leading Lawyers for Business, with 73 practice rankings and 153 leading lawyer listings.
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Press Release February 15, 2024Alston & Bird Recognized by Chambers Global 2024Alston & Bird Recognized by Chambers Global 2024. Nine practices and 22 lawyers are represented in this year’s rankings.Press Release February 15, 2024Alston & Bird Recognized by Chambers Global 2024Alston & Bird Recognized by Chambers Global 2024. Nine practices and 22 lawyers are represented in this year’s rankings.
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Advisories January 10, 2024Federal & International Tax Advisory: YA Global, the Existence of a U.S. Trade or Business, and the Search for Greater ClarityOur Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.”Advisories January 10, 2024Federal & International Tax Advisory: YA Global, the Existence of a U.S. Trade or Business, and the Search for Greater ClarityOur Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.”
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General Publications November 17, 2023“Merci, Mercy Me: Foreign Tax Credit Allowed Against §1411 Tax,” Bloomberg Law, November 17, 2023.This article discusses a recent case that may allow U.S. citizens in certain treaty jurisdictions to file refund claims for foreign tax credits against net investment income tax liability.General Publications November 17, 2023“Merci, Mercy Me: Foreign Tax Credit Allowed Against §1411 Tax,” Bloomberg Law, November 17, 2023.This article discusses a recent case that may allow U.S. citizens in certain treaty jurisdictions to file refund claims for foreign tax credits against net investment income tax liability.
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Press Release June 1, 2023Alston & Bird Increases Practices and Attorneys Recognized in Chambers USA 2023Alston & Bird has received significant recognition in the 2023 edition of Chambers USA: America’s Leading Lawyers for Business, with 68 practice rankings and 149 leading lawyer listings.Press Release June 1, 2023Alston & Bird Increases Practices and Attorneys Recognized in Chambers USA 2023Alston & Bird has received significant recognition in the 2023 edition of Chambers USA: America’s Leading Lawyers for Business, with 68 practice rankings and 149 leading lawyer listings.
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Press Release February 16, 2023Alston & Bird Recognized by Chambers Global 2023Alston & Bird has been recognized in the 2023 edition of Chambers Global, with 9 practices and 18 lawyers cited for excellence.Press Release February 16, 2023Alston & Bird Recognized by Chambers Global 2023Alston & Bird has been recognized in the 2023 edition of Chambers Global, with 9 practices and 18 lawyers cited for excellence.
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Press Release February 17, 2022Alston & Bird Recognized by Chambers Global 2022Alston & Bird has been recognized in the 2022 edition of Chambers Global, with 10 practices and 16 lawyers cited for excellence.Press Release February 17, 2022Alston & Bird Recognized by Chambers Global 2022Alston & Bird has been recognized in the 2022 edition of Chambers Global, with 10 practices and 16 lawyers cited for excellence.
Bar Admissions
- New York
Education
- New York University (LL.M., 1980)
- Fordham University (J.D., 1974)
- Queens College (B.A., 1971)
Memberships
- American College of Tax Counsel, Fellow
- The Tax Review
- International Fiscal Association, USA Steering Committee
- International Tax Institute, past president and current director
- American Bar Association, New York State Bar Association (Sections on Taxation)