Julio M. Jimenez, JD, LL.M., is a Tax Principal in the International Tax Practice at Marks Paneth LLP, where he specializes in international tax advisory services, policy and processes, compliance systems and controversy remediation for the financial sector. He is highly skilled in international tax structuring and planning, financial products, tax treaty issues including the Authorized OECD Approach (AOA) and permanent establishment determinations, hybrid instruments, foreign tax credits, hedging, treasury and risk management strategies and foreign currency issues.
Mr. Jimenez advises his financial services clients on the impact of the Tax Cuts and Jobs Act on international tax provisions, including section 163(j), BEAT, FDII and GILTI. He also assists large international broker-dealers, streamlined broker-dealers, asset managers and investment funds in adapting their policies and systems for section 871(m).
Prior to joining Marks Paneth, Mr. Jimenez served in technical leadership roles at two different national public accounting firms, his own international tax advisory practice and the Internal Revenue Service National Office of the Chief Counsel, where he served on the Headquarters Committee that reviewed IRS examinations for financial services firms and high-net-worth individuals. He drafted IRS guidance on dividend withholding, financial products, foreign currency, international strategies, section 987 regulations, option basket transactions, notional principal contract regulations and distressed debt guidance.
Mr. Jimenez has resolved differences with Canadian, European, Asian and Australian market participants, including Euroclear, Clearstream and SIX, as well as domestic clearers and depositories including Chicago Board of Exchange, NYSE, Bank of New York, Depository Trust and Clearing Corporation. Leveraging his IRS experience, he has resolved numerous IRS examinations in his client’s favor, including cases with up to $2 billion in liabilities.
As a true business advisor, Mr. Jimenez provides consulting services that address the full needs and goals of clients in the financial sector. This includes helping them to develop sound policy processes, including IRS audit, recordkeeping, documentation, anti-abuse and IT policies.
Mr. Jimenez holds a Juris Doctor degree from New England School of Law, a Master of Laws in Taxation from Georgetown Law Center, and a Bachelor’s degree from Boston College. He is a member of the American Bar Association, the D.C. Bar Association, the New York State Bar Association and the Wall Street Tax Association.
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