Stanley Smilack

Of Counsel

• ssmilack@steptoe.com
• vCard
• Washington Office

Mr. Smilack is of counsel in the Washington office of Steptoe & Johnson LLP and a member of the Tax group. Prior to joining the firm, he was tax counsel to Phibro Energy, Inc. and to Salomon Inc. He also practiced tax law in New York and Washington.

International Tax
Mr. Smilack has a diversified federal tax practice focusing primarily on international tax matters. He counsels foreign and domestic business entities in connection with transactions, tax legislative and regulatory developments, tax compliance, and controversies. Mr. Smilack frequently works on acquisition, disposition, restructuring, and financing transactions. He has detailed practical knowledge of the tax rules that apply when such transactions occur in a cross-border context.

Mr. Smilack has significant experience in counseling financial institutions with respect to the tax consequences of their US and foreign activities. He frequently advises multinational enterprises regarding the application of US anti-boycott rules. He has also structured and documented numerous investment funds, established as domestic as well as foreign entities, that invest abroad. In transfer pricing cases, he works closely with in-house personnel and professional advisors to minimize audit risks and maximize planning opportunities. Recent transfer pricing clients include multinational financial institutions and a manufacturer and distributor of branded scientific products. Mr. Smilack has worked with the tax laws of a number of countries, becoming familiar with the types of transactions that can be carried out efficiently in those countries.

Controversies
Over the years, Mr. Smilack has represented a number of clients in federal and state controversies. He has regularly dealt with Internal Revenue Service examiners and appeals officers. He has also handled competent authority proceedings (government to government negotiations over the treatment of a specific taxpayer).

Excise Taxes
Mr. Smilack deals extensively with excise taxes, focusing on the taxes on petroleum products, chemicals, and those that apply to international transactions. He interacts regularly with the Internal Revenue Service regarding the application of the excise tax laws.

Publications

• International Law Advisory - No Change in Treasury Department's List of Boycotting Countries
  October 3, 2006
• International Law Advisory - Treasury Department Issues New List of Countries Participating in Arab Boycott of Israel
  July 7, 2006
• IRS Issues New Tax Regulations on Domestic Reverse Hybrid Entities
  June 11, 2002
• New Tax Proposals Aimed at Foreign-Owned Businesses
  June 6, 2002