David G. Noren focuses his practice on international tax planning for multinational companies. David advises clients on a wide range of “outbound” and “inbound” issues, with a particular focus on the subpart F anti-deferral rules, the application of bilateral income tax treaties, and the treatment of cross-border flows of services and intellectual property rights under transfer pricing and other rules.

Prior to joining the Firm, David served as legislation counsel to the Joint Committee on Taxation in the US Congress where he advised the House Ways & Means Committee, the Senate Finance Committee and other members of Congress on proposed international tax legislation. He played a major role in the development of several international tax bills, including those culminating in the American Jobs Creation Act of 2004.

David also advised the Senate Foreign Relations Committee on the review and ratification of several tax treaties and protocols, carried out the international tax aspects of special investigations and studies requested by members of Congress, and assisted in the Joint Committee staff’s review of large tax refunds in the international area. Prior to working in Congress, David taught in the tax program at the New York University School of Law.

David has testified in congressional hearings on international tax issues and is a frequent writer and speaker on such topics. While in law school, David was an editor of the Harvard Law Review.

David G. Noren focuses his practice on international tax planning for multinational companies. David advises clients on a wide range of “outbound” and “inbound” issues, with a particular focus on the subpart F anti-deferral rules, the application of bilateral income tax treaties, and the treatment of cross-border flows of services and intellectual property rights under transfer pricing and other rules.

Prior to joining the Firm, David served as legislation counsel to the Joint Committee on Taxation in the US Congress where he advised the House Ways & Means Committee, the Senate Finance Committee and other members of Congress on proposed international tax legislation. He played a major role in the development of several international tax bills, including those culminating in the American Jobs Creation Act of 2004.

David also advised the Senate Foreign Relations Committee on the review and ratification of several tax treaties and protocols, carried out the international tax aspects of special investigations and studies requested by members of Congress, and assisted in the Joint Committee staff’s review of large tax refunds in the international area. Prior to working in Congress, David taught in the tax program at the New York University School of Law.

David has testified in congressional hearings on international tax issues and is a frequent writer and speaker on such topics. While in law school, David was an editor of the Harvard Law Review.

Brian H. Jenn focuses his practice on US and international tax matters for US and foreign multinationals and other clients. As former Deputy International Tax Counsel (DITC) for the US Department of Treasury, Brian has extensive experience and insight on the Tax Cuts and Jobs Act (TCJA), having been deeply involved in the process of issuing proposed and final regulations and other guidance implementing the TCJA. Brian also has significant insights on taxation of the digital economy, transfer pricing and US taxation of foreign currencies.

Prior to joining McDermott, Brian spent several years at the US Department of Treasury where he was an attorney advisor, and most recently DITC. While at Treasury, he served as co-chair of the Organisation for Economic Co-operation and Development’s (OECD) Task Force on Digital Economy and as US delegate to the Committee on Fiscal Affairs. In this capacity, Brian led Treasury’s engagement at the OECD on digital tax issues, playing a central role in discussing tax challenges associated with the digitalization of the economy, as well as the development of new international norms for allocating tax rights among countries.

Brian also advises clients with international operations on transfer pricing issues, such as supply chain structuring and intellectual property planning. As US delegate to the OECD’s Working Party 6 throughout the G20-OECD Base Erosion and Profit Shifting (BEPS) project, Brian negotiated major changes to international transfer pricing standards, including changes to the OECD Transfer Pricing Guidelines chapters on intangibles, cost contributions arrangements, risk and recharacterization, and low-value added services.

In addition, Brian was one of the primary drafters of a recently issued detailed set of regulations governing US taxation of transactions involving foreign currencies.

Before joining the Treasury, Brian spent several years in private practice, where he advised clients in various sectors, including technology, pharmaceutical, financial services and consumer products. He handled aspects of international tax planning including foreign tax credits, foreign currency issues, Subpart F, intangible property transfers, transfer pricing and treaty interpretation.

Prior to law school, Brian served as a staff economist to the White House Council of Economic Advisors where he assisted the chairman and members of the council in advising the president on tax policy and other public finance issues. In addition, he served as senior economist to the Joint Economic Committee of Congress where he advised the chair regarding tax policy, including issues related to the economic implications of potential international tax reforms.