Herman B. Bouma has over 30 years of experience in the area of U.S. taxation of income earned in international operations. His work falls into four general areas: legislative, regulatory, transactional, and audit and litigation.
Herm has assisted major U.S. firms and financial institutions with tax planning and analysis, advising on such matters as the structuring of multibillion-dollar international financial transactions, the creditability of foreign taxes, Subpart F, transfer pricing, foreign acquisitions, reorganizations, and restructurings, and compliance with reporting requirements. He has met on behalf of clients with members and staff of the House Ways and Means Committee, the Senate Finance Committee, and the Joint Committee on Taxation, and with the Assistant Secretary of the Treasury (Tax Policy), the International Tax Counsel, and the IRS Associate Chief Counsel (International). Herm was an advisor to the taxpayer in Exxon Corporation v. Commissioner, 113 T.C. 338 (1999) (creditability of the U.K. Petroleum Revenue Tax under sections 901/903), and to the taxpayer in The Coca-Cola Company v. Commissioner, 106 T.C. 1 (1996) (computation of combined taxable income for a possession product under section 936). He is also an advisor to Bloomberg BNA Tax Management, America's leading tax authority.
Herm began his legal career as an attorney-advisor in the IRS Office of Chief Counsel, Legislation and Regulations Division (International Branch), in Washington, D.C. He was the principal author of a number of regulations, including the final foreign tax credit regulations under sections 901/903, participated in the drafting of several pieces of legislation, including legislation providing reporting requirements for foreign-owned corporations, and participated in income tax treaty negotiations with Sweden, Denmark, and the Netherlands Antilles. He was a recipient of the Chief Counsel Award for Outstanding Performance.
Prior to joining Buchanan Ingersoll & Rooney PC, Herm was a partner with the law firms of McClure & Trotter, H. B. Bouma, and Caplin & Drysdale in Washington, D.C.