Andrey Krahmal

Call: 2004    

Practice Overview


JD (Harvard) LLM (NYU) Admitted to the bar of the State of New York 2004

 

Andrey is US tax attorney admitted to the New York Bar. He has 10 years of experience representing individuals, trusts, partnerships and companies of all sizes in connection with their inbound and outbound US tax issues (including FATCA matters). He frequently works closely with both UK and US based professional advisers, accountants and lawyers to provide clients with robust and commercial US tax solutions. He is acutely aware of US tax issues faced by UK and Europe based persons and entities with a US connection. Andrey advises in respect of all aspects of US federal taxation matters and sometimes on state taxation matters.

 

He acts exclusively for the taxpayer and gives advice and representation in respect of all types of disputes with the US Internal Revenue Service including tax investigations, enquiries and settlement negotiations, he also assists with all types of applications and appeals within the IRS, Tax Court and higher courts.

 

Education and Background

Andrey studied law at Harvard Law School and received a master's degree (LLM) in tax law at New York University being admitted to the Bar of the State of New York in 2004. He worked as an associate for Cahill Gordon & Reindel LLP before joining the "magic circle" law firm Allen & Overy LLP in London as a US tax lawyer.

 

Qualifications and Professional Associations

 

  • BA (Lehigh University); J.D. (Harvard Law School); LLM (Tax) (New York University);
  • Member of the Bar of the State of New York

 

Recent Practice

A sizable portion of Andrey's tax practice has, over the last 10 years, involved international capital markets transactional, tax structured finance, derivatives, corporate mergers and acquisitions, private equity structuring, aspects of portfolio investments, and FATCA matters.

 

More recently, Andrey has also been providing US/UK tax advice for a number of very high profile film and entertainment professionals, fashion and media businesses, and UK/US based sports personalities, as well as banking and investment professionals and companies.

 

Andrey worked in the US tax group of a "Magic Circle" law firm on a broad range of matters including fund formation and management, multiple M&A, capital markets US inbound and outbound transactions, liability management, structured finance (cross-border repos, foreign tax credit trades, US withholding trades), mergers and acquisitions (check-the-box, section 338, foreign tax credit, and treaty planning) and spin-offs; offerings of equity and debt securities (including bearer and registered notes, warrants and certificates programs); derivatives trades documented under ISDA agreements; lobbying efforts relating to Subpart F provisions; FATCA implementation and compliance matters.

 

Tax Shelter Investigations

 

Andrey advised with respect to litigation, administrative law, and tax law matters. Over the course of more than 3 years he represented a non-US investment bank that was involved in the implementation of a US tax shelter involving options trading. Such representation occurred in the context of the US Senate tax shelter inquiry and hearings.

 

FATCA

 

Andrey has advised on FATCA implementation for several major international banks and a major UK financial institution. Andrey commented extensively on FATCA provisions and their application in the European context and the implication such provisions may have for both the participants in the bank lending and capital markets and to the individual account holders in mainstream banks.

 

Participation in Industry Groups

 

Andrey participated in discussions among the members of North American Tax Committee and European Tax Committee of ISDA in representing the interests of his former law firm and acting as counsel for ISDA. Andrey assisted the European Tax Committee in light of the changes to ISDA standard legal documentation used in derivatives transactions as a result of the HIRE Act including FATCA provisions.

Publications and Press Citations

 

Andrey has written and published numerous external and internal papers, client alerts, and publications, including several law review articles. One of Andrey's law review articles was cited as definitive guidance by a US District Court, and another was cited in a subject matter area treatise.

 

Andrey has undergone extensive media training and provided commentary on the US tax legal aspects in various news sources, including the Financial Times, South China Morning Post, Bloomberg News, Tax Review and Tax Journal.

 

1. How FATCA applies to non-US funds, Tax Journal (1 August 2014)

Use this link, please:

http://www.taxjournal.com/tj/articles/how-fatca-applies-non-us-funds-31072014

 

2. Defensive moves: Tax considerations for US citizens working or residing in the UK, Taxation (30 April 2014)

Use this link, please:

http://www.taxation.co.uk/taxation/Articles/2014/04/29/323901/defensive-moves

 

3. FATCA and IGA: defining investment entities

 

Use this link please:

http://www.taxjournal.com/tj/articles/fatca-and-iga-defining-investment-entities-21052015

 

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JD (Harvard) LLM (NYU) Admitted to the bar of the State of New York 2004

 

Andrey is US tax attorney admitted to the New York Bar. He has 10 years of experience representing individuals, trusts, partnerships and companies of all sizes in connection with their inbound and outbound US tax issues (including FATCA matters). He frequently works closely with both UK and US based professional advisers, accountants and lawyers to provide clients with robust and commercial US tax solutions. He is acutely aware of US tax issues faced by UK and Europe based persons and entities with a US connection. Andrey advises in respect of all aspects of US federal taxation matters and sometimes on state taxation matters.