Trien Rosenberg Rosenberg Weinberg Ciullo & Fazzari, LLP

Trien Rosenberg, founded in 1970, is a New York metropolitan area professional services firm with offices in New York, New York, and Morristown, New Jersey. Trien Rosenberg participates in the profession's self-regulation effort through peer review, and we are members of the Securities and Exchange and Private Company Practice Sections of the American Institute of Certified Public Accountants.

Trien Rosenberg's International Tax Group provides a wide range of services for foreign companies and foreign financial institutions operating in the U.S. as well as U.S. companies and financial institutions operating abroad. The core practice of the International Group involves tax planning for cross-border transactions. The International Group also provides legal representation in mergers, licensing, asset acquisitions, corporate reorganizations, acquisitions of real property, and estate and trust matters for nonresidential individuals.

, Partner, is Director of Tax Services for the firm. He is a former Adjunct Professor of Taxation at Pace University, Graduate School of Business. He has lectured at seminars in the field of taxation sponsored by the New York and New Jersey State Society of Certified Public Accountants, International Tax Journal, World Trade Institute, and various other professional organizations. Bill has authored articles for professional journal, including The CPA Journal, Taxes Magazine and The Practical Accountant.

He was a member of the Tax Simplification Committee of the American Institute of Certified Public Accountants Tax Division and the Corporations and Shareholders Taxation Committee. He is a member of both the Bankruptcy and the Corporation Tax Committee of the New York State Bar Association. In addition, he has served as a member of the Federal Tax Committee for the New Jersey Society of Certified Public Accountants and the International Tax Committee for the New York State Society of Certified Public Accountants. Prior to Trien Rosenberg, Mr. Rosenberg was an International Tax Specialist at a major accounting firm.

Mr. Rosenberg's professional memberships include: American Institute of Certified Public Accountants; New Jersey Society of Certified Public Accountants; New York State Bar; and the New York State Society of Certified Public Accountants. He holds a Bachelor of Business Administration from George Washington University; a Juris Doctor degree from Brooklyn Law School; and an LLM degree (taxation) from New York University School of Law.

concentrates his practice in the area of tax planning for privately held transnational business, with emphasis on intercompany transactions. Working closely with foreign counsel, Mr. Ruchelman has represented companies in matters involving the I.R.S., and has counseled corporate clients on transfer pricing issues, worldwide reorganizations, and structuring investment in the United States. He has authored numerous monographs on international taxation for a variety of publications and treatises. In addition, Mr. Ruchelman is a frequent lecturer on that subject, having spoken at the Practicing Law Institute; New York University Tax Institute; the American Bar Association; the International Fiscal Association; and other organizations. He chaired the introductory and intermediate seminars on international taxation for Executive Enterprises. Mr. Ruchelman was a Senior Attorney in the Legislation & Regulations Division of the Office of Chief Counsel, Internal Revenue Service, where he participated in the negotiation of income tax treaties and the development of legislative and regulatory policy affecting international business. Prior to that, he was an Attorney Adviser to the Hon. Charles R. Simpson, U.S. Tax Court. Mr. Ruchelman was an international tax partner for one of the major international accounting firms where he practiced for eight years, and represented clients involved in cross-border trade and investment.

He is a former Vice Chair of the Committee on U.S. Activities of Foreigners and Tax Treaties, Section of Taxation, American Bar Association and a former member of  the National Council of the International Fiscal Association -- USA Branch.

Mr. Ruchelman received his J.D. Degree with honors from George Washington University (1972), and his undergraduate degree from Brooklyn College (1968).

PROFESSIONAL ARTICLES:

- “Outbound Acquisitions: European Holding Company Structures,” Practicing Law Institute, Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings (2007). 

-  “Home Thoughts From Abroad: Foreign Purchases of U.S. Homes,” Tax Notes (9/23/07), p.863. 

-  “Preimmigration Income Planning and Ethical Issues in Representing The Foreign Individual,” New York University Summer Institute, International Taxation (July 2006)

- "Canadian Financing of U.S. Operations in Light of Treaty Changes: Overuse of Hybrid Entities," Vol. 26, No. 5 Intertax 154 (May 1998).

- "The Good, The Bad, & The Ugly: Recent Cases Addressing International Tax Transactions," Vol. 24, No. 2 International Tax Journal 1(Spring 1998).

- "SDI Netherlands Begets Confusion by I.R.S., Tax Court, and Commentators," Vol. 77, Number 11 Tax Notes 841 (November 17, 1997).

- "European Approaches to Hybrid Entities and Financing Structures: An Introduction," Vol. 17, Number 18 Tax Notes International 1487 (May 5, 1997).

- "SDI Netherlands Case -- A Windfall for Dutch Licensing Companies,"Vol. 23, No. 11 Tax Planning International Review 11 (November 1996).

- "Highlights of Revised Model Income Tax Treaty Issued by U.S. Treasury Department," Vol 25, No. 12 Tax Management International Journal 803 (December 13, 1996).

- "Cross-Border Planning Under Check-The-Box Proposal," Vol. 23 No. 7 *Tax Planning International Review 3 (July 1996).

- "U.S. Taxation of International Operations: Trends and New Developments," Vol. 22 No.1 International Tax Journal 1 (Winter 1996).