Overview
Allen joined Burr's Corporate and Tax group in 2012 after many years with a prominent Dallas, Texas law firm. Allen works with U.S. and foreign clients involved in various industries providing corporate, mergers and acquisitions (M&A), private equity, tax, international trade, export controls, and compliance strategies.
Corporate, M&A, and Private Equity
Allen’s corporate, M&A, and private equity practice involves many aspects of corporate law including mergers, acquisitions and dispositions, foreign direct investment, joint ventures, corporate and fund formations, private placements, and tax-free reorganizations. Allen’s tax background helps him regularly form and structure LLCs that include profits interests and complicated waterfall distribution provisions.
Tax Practice
Allen has been named to The Best Lawyers in America, Tax Law. His tax background includes both tax planning and tax controversy matters. Allen’s tax planning experience includes individual, “C” corporation, “S” corporation, partnerships/LLCs, executive compensation, and international tax matters, to name a few. His tax controversy work includes complex audits, IRS Appeals negotiations, large collections matters, penalty abatements (domestic and international), Tax Court litigation, and various types of voluntary disclosures.
International Trade and Compliance
In his international trade and compliance practice, Allen advises clients on export control matters involving the Export Administration Regulations (the “EAR”) and the International Traffic in Arms Regulations (the “ITAR”), transactions involving the Committee on Foreign Investment in the U.S. (“CFIUS”), Foreign Corrupt Practices Act (“FCPA”) matters, and sanctions involving the Office of Foreign Assets Control (“OFAC”).
In his EAR and ITAR work, Allen helps business classify their products and technology under the EAR and the ITAR, as well as comply with applicable restrictions by using appropriately tailored compliance policies and training programs. On the anti-corruption and sanctions front, Allen tailors corporate policies to his clients’ particular products, technology, services, customers, workforce and relevant international footprint. Allen also helps clients with third party due diligence related to the ever-changing OFAC sanctions landscape.
CFIUS and Foreign Direct Investment
Allen has also represented foreign buyers and U.S. sellers in foreign direct investment transactions involving CFIUS considerations, some resulting in notices and declarations that the Committee ultimately approved. His CFIUS experience also includes negotiating conditions for CFIUS approval, including national security agreements designed to protect U.S. national security, and working with the Committee to restructure companies that are subject to ongoing CFIUS monitoring following Committee approval.
Offshore Account Compliance
Allen has represented over 100 U.S. citizens and residents, dual citizens and their families, and related entities in properly reporting their offshore holdings for U.S. tax purposes, and in reconciling previous compliance missteps, failures, and deficiencies. Through this, he has represented taxpayers in every iteration of the IRS’s Offshore Voluntary Disclosure Initiatives such as the OVDP (including “Opt Outs”), Streamlined Procedures, and others.
Honors & Recognitions
- Listed in The Best Lawyers in America®: Tax Law since 2022
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Professional Activities
- Alabama State Bar (Tax Section)
- American Bar Association (Tax and International Law Sections)
- Dallas Bar Association (Tax Section)
- Texas Bar Association (Tax Section)
- Dallas Association of Young Lawyers
- Birmingham Bar Association
Paralegal/Assistant
Legal Practice Assistant
Stephanie Cruce
(205) 458-5236
scruce@burr.com