Practices

Bar & Court Admissions

  • State Bar of New York
  • England (Barrister and Solicitor)
  • U.S. Tax Court 

Professional Affiliations

American Bar Association

Committee on Taxation of Business Entities, New York City Bar

International Fiscal Association

New York International Tax Club (Chairman)

New York State Bar Association

Education

L.L.M, Federal Taxation, New York University

B.A, University of Westminster, London

Photo of Ian  Shane

Ian Shane

Partner
New York
T: 212.730.7700
F: 212.730.7725
Profile
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Full Bio

Ian Shane is a partner and Chair of M&R’s Tax Department. He routinely advises clients with respect to U.S. corporate tax planning and structuring for a variety of transactions, including inbound and outbound transactions, mergers and acquisitions, and corporate restructuring.

Mr. Shane also provides tax advice to partnerships and LLC’s on domestic tax issues and counsels U.S. companies on international tax planning issues arising from investing overseas, particularly in Europe and Asia. He has advised on choice of entity, check-the-box regulations, as well as cross border financings, transfer pricing, and inbound and outbound asset and stock transfers.

In addition to advising U.S. companies, Mr. Shane has represented foreign companies investing in the U.S., providing advice on cash flows in and out of the U.S. and structuring arrangements that take into account foreign and domestic tax rules to minimize U.S. and foreign tax liability.

Mr. Shane has published a series of articles on tax and business subjects for various publications, including British Airways’ Business Life Magazine.

Education

Mr. Shane earned his L.L.M., in Taxation, from New York University. He received his B.A. with Honors, in Law (J.D. equivalent), from the University of Westminster, London. 

Past Experience

Prior to joining M&R, Mr. Shane held several positions as a Partner and Of Counsel at AmLaw 100 and international law firms in London and New York.

Representative Matters

  • Anti-Avoidance Advice: Mr. Shane assisted an established U.S. business in structuring a new outsourcing operation in Asia, including advice on controlled foreign company issues, economic substance requirements, transfer pricing matters and advice on repatriation of profits back to the US.
  • Change of Control Tax Issues:  Mr. Shane provided advice to a U.S. corporation with substantial carried forward NOL’s on potential ‘change of control’ issues arising from the conversion of loans into equity and the restructuring of its equity.
  • Inbound Investment Structuring: Mr. Shane represented a UK hospitality business in establishing an operation in the U.S. for the first time, including tax structuring and advice on federal, state and local tax issues.
  • International Tax Structuring: Mr. Shane structured the establishment of a subsidiary in New York of a broker/dealer business based in London. He effected a tax structuring involving a corporate blocker and an operating LLC so that profit interests could be given to employees. Mr. Shane also advised owners of the business, who had not previously done business in the U.S. on all federal, state and city tax issues relating to their new U.S. subsidiary.
  • International Tax StructuringMr. Shane successfully assisted his client, a major apparel retailer in the Northeast U.S., in opening its first store outside of the country (Amsterdam). He performed all of the U.S. international tax work for the client, working closely with Dutch tax advisers. At the same time, he helped the client form a Mexican subsidiary for the Dutch holding company and acquired a garment production facility, equipment and workforce to produce the clothes for the client’s new European venture. Mr. Shane coordinated the Dutch, Mexican and U.S. components of the project and advised on U.S. international tax issues.  
  • Litigation Settlement Tax Issues: Mr. Shane provided advice to a New York based private equity fund on the tax consequences of investing in litigation claims.
  • Mergers and Acquisitions: Mr. Shane acted for a U.S. subsidiary of a well-known Asian electronics company in a number of stock acquisitions in which the client made section 338(h)(10) elections to treat the stock acquisition as an asset acquisition for federal income tax purposes.
  • Representation Before IRS:  Mr. Shane advised a variety of individual clients advising them regarding the disclosure of offshore financial accounts through the IRS’s Offshore Voluntary Disclosure Program and Streamlined Process.
  • Tax-Free Spin-Off: Mr. Shane advised a U.S. health care group on a tax free spin-off of its ambulance subsidiary to its shareholder as part of a corporate restructuring, and on golden parachute payments which arose as part of the restructuring.
  • Tax Structuring Share Transfers:  Mr. Shane provided tax advice and structured a buy/sell agreement for an S corporation whereby a corporation purchases life insurance on its shareholders and all shareholders and the corporation enter into a buy/sell agreement so, in the event of a shareholders’ death, the corporation can use the proceeds of the life insurance policy to purchase the deceased shareholder’s shares from his or her estate.  

Publications

Past Speaking Engagements