M E M O R A N D U M
January 20, 2010
TO: Distribution
FROM: John M. Staples
RE: Appointment of Michael Danilack as IRS Deputy Commissioner (International) LMSB
I am pleased to announce that our partner, Mike Danilack, has been appointed Deputy Commissioner (International) for the Large and Midsize Business Unit (“LMSB”) of the IRS. In this role, Mike will oversee the competent authority process and all the IRS’ international tax compliance and audit efforts.
Mike is no stranger to the IRS. From 1995 to 2000, Mike served as the Associate Chief Counsel (International), heading the division in IRS Chief Counsel’s office responsible for the interpretation, enforcement, and litigation of the international provisions of the Code and the tax treaties of the United States. Also, from 1993 to 1995, Mike served as Assistant to the Commissioner, where he acted as the IRS Commissioner’s liaison on a variety of matters of tax administration, law, and policy.
Mike will return to the IRS with 10 years of additional private sector experience, first as a principal in the national office of Deloitte Tax, and then as a partner at Burt, Staples & Maner (“BSM”), both in Washington, D.C.
Mike has an unusually strong background in the tax withholding and reporting area, as many of our clients know. During his previous government service, he oversaw the section 1441 withholding tax regulation project and the development of the qualified intermediary (“QI”) regime. During his time at BSM, he has worked on many cutting-edge tax withholding, reporting and QI issues. Mike should prove valuable to his new IRS and Treasury colleagues in their efforts to ensure compliance in this area and to implement the new withholding tax regime set forth in the Foreign Account Tax Compliance Act (“FATCA”), which is expected to pass Congress soon.
For those clients who have worked with Mike, you will appreciate how much we will miss both his excellent legal judgment and the depth of his technical knowledge. On a personal level, I will particularly miss Mike, since we worked together first at Sutherland, Asbill & Brennan, then as Assistants to IRS Commissioner Richardson, and then later as partners at BSM. It is very difficult to see him leave, but I hope our career paths will someday allow us to practice together again.
Please join me in wishing Mike the best of luck in his new position.