Mindy Piatoff Daynes

MINDY PIATOFF DAYNES has a broad based tax background encompassing U.S. and international tax planning. She provides clients with strategic advice on topics including the tax impact of investing in U.S. companies and real estate (FIRPTA), choice of entity, changes in accounting methods, the tax treatment of construction allowances, cancellation of indebtedness, deductibility of related party payments and associated withholding tax, investment in controlled foreign entities, utilization of foreign tax credits, analysis of tax treaties, and U.S. reporting requirements of foreign financial assets. Ms. Piatoff Daynes also assists with due diligence engagements to identify potential tax exposure.

Ms. Piatoff Daynes also advises individuals regarding the tax treatment of becoming U.S. residents subject to worldwide tax and reporting requirements, the use of treaty-based tax return positions and foreign earned income exclusions for U.S. citizens and residents working abroad. She also assists clients with the Internal Revenue Service (“IRS”) voluntary disclosure program for offshore accounts.

Ms. Piatoff Daynes has particular expertise in transfer-pricing with an effective combination of both government and private practice experience. As Branch Chief and Acting Director of the APA Program she developed an in depth/hands-on knowledge of APAs, and the Competent Authority process. Ms. Piatoff Daynes continues to assist clients with the negotiation of unilateral and bilateral APAs, transfer pricing planning and implementation, representation in IRS tax examinations and with the analysis of alternative dispute resolution techniques including the Appeals and the Competent Authority process.

Ms. Piatoff Daynes received her law degree from the University of Connecticut School, her Masters in Tax from the University of Hartford and a Bachelor of Science in Accounting from New York University. She is a member of the American Bar Association, the American Institute of CPAs and the New York Society of CPAs.