New IRS Regulations on Digital Asset Transactions: Gross Proceeds and Basis

Roger Brown has more than 26 years of experience with the international tax issues impacting banks, insurance companies, and asset management complexes. This experience has been with law and accounting firms, the national office of the Internal Revenue Service, and as an adjunct professor of International Tax at the Georgetown University Law Center. As a member of the international tax division of the IRS (Chief Counsel) national office for almost 10 years, Roger served in a several transfer pricing and technical tax branches before being promoted to the positions of (i) Assistant Branch Chief for the Financial Institutions and Products Branch in the international tax division, and then (ii) Special Counsel to the Associate Chief Counsel (International).

Amir Marmar worked for over 15 years in Accounting & Finance before leaving corporate America in November of 2012 to start JFDI. Amir’s vision was to create an organization that would develop a new standard in financial services by integrating new technologies with the best practices.

Keith Kelly specializes in entertainment law, covering all aspects of global transactions including rights procurement, development, production, licensing, and distribution of movies, documentaries, scripted and unscripted television, and original sports programming. He also advises studios and media firms on music, concert bookings, sponsorships, and live events.

Philipp Behrendt is licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures.  He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets.

Prior to joining the firm, Mr. Behrendt worked for more than 5 years for a leading German tax firm, where he focused on representing wealthy individuals and companies in global tax settings, cross-border investigations and audit matters, as well as tax compliance issues arising from internationally functioning matrix structures.  Mr. Behrendt obtained experience in  handling complex voluntary disclosure issues for U.S. and other international companies, representing clients in German tax and criminal courts as well as in international money laundering investigations stemming from tax avoidance structures of the client’s business partners and customers. He has worked with client tax teams throughout Europe, the US as well as in the Arabic region. 

Mr. Behrendt is an LL.M. graduate of the University of Southern California (USC) Gould School of Law, an LL.M. graduate of the University of Osnabrueck (Germany) as well as holds a law degree from the University of Greifswald (Germany).