John D. Barlow

John works with corporate tax departments on cross-border transactions and restructurings. He relies on his tax planning, controversy, and in-house experience to develop practical solutions that meet his clients’ tax, accounting, and commercial needs.

As part of his practice, John assists clients in vetting and implementing complex cross-border transactions and transfers of IP. He regularly advises clients on Subchapter-C, foreign tax credit, GILTI/Subpart-F, sourcing, and withholding issues related to these transactions. He also makes sure to work with all in-house stakeholders to ensure successful implementation.

In addition, John has substantial experience working with corporate treasury departments to provide practical solutions to tax issues that arise from cross-border treasury activities, including cash pooling, FX hedging programs, and internal debt restructurings. 

John also regularly assists clients with their IRS-audit defense of cross-border and financial transactions at the exam and appeals level.

His clients include companies in the consumer-product, defense, digital, FinTech, pharmaceutical, and software industries.