Background
Ruchelman, Stanley C. was born on November 14, 1947 in Brooklyn, New York, United States.
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Stanley C. Ruchelman
Edit ProfileEducation
Brooklyn College of the City University of New York (Bachelor of Arts, 1968). George Washington University (Juris Doctor, with honors, 1972).
Career
Worked at Ruchelman Law Firm (New York, NY) specializing in International Tax, International Estate Planning, Laws Affecting Foreign Investors in the United States. Admitted to the bar, 1973, District of Columbia. 1986, New York.
Law Clerk, United States.
Tax Court, 1972-1974. Attorney Advisor, Legislation and Regulations Division, Office of Chief Counsel, Internal Revenue Service, 1974-1976. Partner: Touche Ross, International Tax, 1981-1985.
Author: "SDI Netherlands Case Licensing Companies" vol. 23 No. 11 The Planning International Reniel 11 (November 1996). "Highlights of Revised Model Income Tax Treaty Issued by United States.
Treasury Department, vol 25 No. 12 Tax Management International Journal 903 (December 13, 1996). "Cross-Border Planning Under Check-The Box Proposal," Volume 23 No.
7 Tax Planning International Review 3 (July 1996). "United States. Taxation of International Operations: Trends and New Developments," Volume 22 No. 1 International Tax Journal 1 (winter 1996).
"Final United States. Transfer Pricing Penalty Regulations Issued," Volume 23 No. 3 Tax Planning International Review 3 (March 1996).
"New Temporary Regs on Stock Transfers to Foreign Corporations Analyzed," Volume 12 No. 17 Tax Notes International 1333 (1996). "Structuring the United States.
Investment," United States. Taxation of Foreign Controlled Business, Chapter 2 (Warren, Gorham & Lamont 1995). "United States Penalties in International Tax Planning," International Tax Planning, p.
313 (Kluwer Law International 1995). Protocol to United States.- Canada Income Tax Treaty -- Contentious Issues Addressed Through Novel Approaches, Volume 21 No. 11 Tax Planning International Review 3, November 1994.
"Underlying Policy of the Regulations," Transfer Pricing Handbook, p.3, Wiley, 1993. "United States: Rules Limiting Interest Deductions Are Proposed by IRS", 45 Bulletin for International Fiscal Documentation 515, November 1991". "Transfer Pricing of Intangibles After the Section 482 White Paper", Volume 71, No.
1 J. Tax 38, July 1989. "Section 482--The Super Royalty Provisions Adopt the Commensurate Standard", 41 Tax Lawyer 611, Spring, 1988. Member: American Bar Association (Past Vice-Chair, International Tax Committee, Section of International Law and Practice.
Member, Committee on United States. Activities of Foreigners and Tax Treaties, Section of Taxation). International Fiscal Association USA Branch (Member, USA, Council).
Membership
Member: American Bar Association (Past Vice-Chair, International Tax Committee, Section of International Law and Practice. Member, Committee on United States. Activities of Foreigners and Tax Treaties, Section of Taxation).
International Fiscal Association USA Branch (Member, USA, Council).
