Seth Green focuses on structuring the operations of a wide range of private equity investors and multinational corporations. He has advised clients on issues related to internal and external financing, deferring recognition of foreign operating income, and managing the use of foreign tax credits. His work also includes issues surrounding cross-border reorganizations (including inversions) and other structures for taxable and tax-free dispositions and acquisitions.
During the 1990s, Seth spent four years with the United States Treasury Department’s Office of Tax Policy, first as an attorney-advisor and then as an associate tax legislative counsel. At Treasury, Seth developed and reviewed administrative guidance, including regulations and revenue rulings on a wide variety of issues. In addition, he provided analysis and advice on the tax policy implications of legislative proposals. His major areas of focus included consolidated return regulations, leasing transactions, partnership taxation, corporate divisions, and reorganizations.
Seth has published in the Journal of Corporate Taxation, and has served as an adjunct professor at the Georgetown University School of Law. He is a member of the American Bar Association Tax Section, and the District of Columbia Bar Association Tax Section. He holds an AB degree in mathematics from Harvard College; a JD degree from University of Maryland School of Law; and an LLM degree in taxation from New York University School of Law.