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Robert E. Culbertson

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Rob Culbertson is a member of the Tax Practice Group.  His practice focuses on international tax planning and controversy resolution.

The former Associate Chief Counsel (International) for the Internal Revenue Service (IRS) has more than 25 years of international taxation experience, comprising both the private and public sectors.  Most recently, Mr. Culbertson represented some of the largest US- and non-US- based multinationals in connection with their structural and transactional tax planning, including advice concerning cross-border acquisitions, restructurings, and financings.  He also represented clients before the IRS, the U.S. Treasury, and Congress, regarding audit controversies, rulings, regulations, and legislative issues.

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On March 13, 2020, the President issued a proclamation declaring a national emergency regarding the global outbreak of the COVID-19 virus (the “COVID-19 Emergency”).  Subsequently, FEMA approved all states and the District of Columbia for major disaster declarations to provide federal emergency assistance.  The Federal Government and state governments have also taken unprecedented preventative and proactive measures to slow the spread of COVID-19 by instituting stay-at-home orders and significantly curtailing travel.  These restrictions have caused concerns regarding the application of the U.S. tax residency rules to nonresidents who are unable to leave the United States due to the state of emergency.  In response, Treasury and the IRS issued Rev. Proc. 2020-20 to provide important relief under the substantial presence test for nonresidents unable to travel due to the COVID-19 Emergency.
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