Alan I. Appel ’76

Professor of Law
Director, International Tax Program

Alan I. Appel ’76

Professor Alan I. Appel specializes in international and domestic tax planning involving taxation of mergers and acquisitions, partnerships, joint ventures, limited liability companies and tax controversy matters. Prior to joining New York Law School, Professor Appel began his career as a trial attorney in the Office of Chief Counsel, Internal Revenue Service in Washington, D.C., and New York City. On behalf of the American Bar Association Tax Section, Professor Appel had the primary responsibility for drafting and submitting comments to the U.S. Treasury Department and IRS concerning the scope of the guidance provided by the proposed regulations under Section 1446 of the Internal Revenue Code and was also asked by the Office of the Chief Counsel to train its attorneys on this issue. Professor Appel published four articles on the Section 1446 regulations in The Journal of International Taxation, Tax Management Memorandum, and Tax Management International Journal.

Professor Appel is on the Board of Advisors for the Journal of International Taxation and theJournal of Taxation and Regulation of Financial Institutions. He has published articles inThe Journal of Taxation, Tax Management Memorandum, Tax Management International Journal, The Journal of International Taxation, the New York Law Journal and the Westchester Bar Journal. He was formerly the Chair of the U.S. Activities of Foreigners and Tax Treaties Committee of the American Bar Association Section of Taxation and currently sits on the Section’s nominating committee. He is also a Fellow of the American College of Tax Counsel.

Professor Appel has appeared on both radio and television discussing various income tax issues. He was also recently featured in “Taxpayers Strained by New FATCA Requirements” in AccountingToday.com, a leading provider of online business news for the tax and accounting community, concerning the Foreign Account Tax Compliance Act’s new requirements.

Professor Appel holds a J.D. from New York Law School and an L.L.M. from New York University. Professor Appel began his career in academia as an adjunct professor at New York Law School in 2009 and joined the faculty full-time in 2013. At New York Law School he is also the Director of the International Tax Program. He joins the Law School after spending the past 13 years as Counsel at Bryan Cave LLP.

Bloomberg BNA 53 Tax Management Memorandum 43. “Tax Structuring of Foreign Investment in U.S. Real Estate with a N.Y. Twist” by Alan I. Appel, Esq. and Jack Mandel, Esq. January 30, 2012.

70th NYU Tax Institute, Tax Structuring of “Foreign Investment in U.S. Real Estate with a  N.Y. Twist.” By Alan I. Appel, John P. Barrie, Michael Hirschfeld and Michael J.A. Karlin. 2012.

Journal of Taxation of Financial Institutions 25J’Tax’N F Inst. 5 “Structuring Investments by Foreign Persons in U.S. Real Estate.” 2012.

68th NYU Tax Institute, Chapter 3, “2009 – A year of Increased Focus on International Tax Reporting.” 2010.

BNA Tax Management International Journal. February 13, 2009. “Living with the Final Partnership withholding Regulations.” 2009.

BNA 47 Tax Management Memorandum 9. May 1, 2006. “Kissing the Blarney Stone: A practical guide to structuring Partnership Agreements and Limited Liability Company Operating Agreements in light of the Section 1446 Regulation.”

Journal of International Taxation, “At Long Last …Final Regulation on Foreign Partners Withholding (Prt1) “Uncle Sam meets Uncle Scrooge The temporary Regulations on Foreign Partners Withholding (Prt2). 2005.

Journal of Taxation of Financial Instruments, 17 J Tax’n F Inst 63. “Section 1446 Regulation proposed for withholding on effectively connected income allocable to Foreign Partners” 2004.

Journal of Taxation of Financial Instruments, 14 J Tax’n F Inst 51. “Due Diligence in International Mergers and Acquisitions.” 2004.

9 Journal of International Taxation 1. “Inbound Tax Planning for Individual Foreign Investors and Entrepreneurs.” January 1998.

21 Westchester Bar Journal 203. “New Limited Liability Company Legislation in New York.” 1998.

39 Tax Management Memorandum 9. “One Step Forward, One Step Back:  Recent Changes in the Nonrecognition Treatment of Preferred Stock and Warrants.” 1998.

86 Journal of Taxation 2. “International – Tax Court Ends The “Cascading Royalty” Problem.” February 1997.

5 Journal of International Taxation 3.  “U.S. Approves Six Treaties: Canada Reconsiders Regs: Mexico Slows Negotiations.” March 1994.

22 TMIJ 367 “Overview of the United States-Israel Tax Treaty, as Amended by the 1993 Protocol.” 1993.

2014

Moderator, “Joint Current Developments: FAUST, FLF, Transfer Pricing and USAFTT,” Section of Taxation, American Bar Association, January 2014 (Phoenix, AZ)

2013

Speaker, “19th Annual Canada-U.S. Cross-Border Tax Update,” Bloomberg BNA, October 2013 (Toronto, ON)

Co-Speaker, “FATCA Compliance for Fiduciaries,” CBIT Education Inc.’s 28th Annual Spring Tax Day, June 2013

Speaker, “Understanding U.S. Taxation of Foreign Investment in Real Property,” Bloomberg LP’s Current U.S. Tax Planning for Foreign-Controlled Companies, June 2013

Moderator, “Understanding Tax Issues for Foreign Persons Investing in U.S. Real Estate,” ABA Section of Taxation’s Midyear Meeting, January 2013

2012

Bloomberg BNA, Inbound Real Estate Investment (New York, NY)

NYU Tax Institute, International Planning (New York, NY)

Bloomberg BNA, Cross-Border Real Estate (Canada)

ABA Tax Section, IRC Section 1446 (San Diego, CA)

NYU Tax Institute, IRC Section 897 (New York, NY)

2011

NYU Summer Tax Institute, International Tax Planning (New York, NY)

2010

NYU Summer Tax Institute, International Tax Planning (New York, NY)
Executive Enterprises, International Taxation Boot Camp, International Tax Planning (New York, NY)

2009

NYU Tax Institute, International Tax Planning (New York, NY)

NYU Summer Tax Institute, International Tax Planning (New York, NY)

ABA Tax Section, International Tax Planning (New Orleans, LA)

2008

NYU Summer Tax Institute, International Tax Planning (New York, NY)

New York State Bar Assn., International Tax Planning (New York, NY)
ABA Tax Section Fall Meeting, International Tax Planning (San Francisco, CA)

2007

ABA Tax Section Fall Meeting, International Tax Planning (Vancouver, BC)

NYU Summer International Tax Institute, International Tax Planning (New York, NY)

New York City Bar, International Tax Planning (New York, NY)

Tax Management Advisory Board, International Tax Planning, Section 1446 (New York, NY)

2003

ABA Tax Section Midyear Meeting, International JV Tax Planning (San Antonio, TX)

2002

Executive Enterprises Institute, International M&A Tax Due Diligence (New York, NY)

ABA Tax Section Fall Meeting, Foreign Investment in US _ REITS (Los Angeles, CA)

ABA Tax Section May Meeting, Cross Border Licensing of IP to US (Washington, DC)

2000

ABA Tax Section Midyear Meeting, Cross-Border Real Estate Transactions between U.S.-Mexico (San Diego, CA)

1999

Executives Enterprises, International M&A Due Diligence (New York, NY)

World Trade Institute, Advanced International Taxation (New York, NY)

NYC Bar, Taxation of Foreign Investors (New York, NY)

1998

ABA Tax Section Annual Meeting, Foreign Investment in U.S. Real Estate (Toronto, ON)

1997

Tax Executives Institute, Check the Box in M&As (New York, NY

WNYW Channel 5 Fox TV, Last Minute Tax Tips (New York, NY)

ABA Tax Section Midyear Meeting, Withholding Tax on Phantom Gain (Scottsdale, AZ)

1996

ABA Tax Section Annual Meeting, Withholding Tax on Phantom Gain (Orlando, FL)

WNYW Channel 5 Fox TV, Last Minute Tax Tips (New York, NY)

1995

NYU Institute on Federal Taxation, Partnerships and Pass-Through Entities (New York, NY)

Chesbonot, Planning under the New U.S.-Israel Income Tax Treaty (New York, NY)

World Trade Center Tax Institute, U.S. Taxation of Foreign Persons (New York, NY)

1993

ABA Annual Meeting, Fundamentals of Real Estate Transactions – Legislative Update (New York, NY)

ABA Tax Section May Meeting, New U.S.-Dutch Tax Treaty – Effect on U.S. Real Estate Investment (Washington, DC)

American-Israel Chamber of Commerce, New U.S.-Israel Tax Treaty

ABA Tax Section Annual Meeting, Tax Treaty Update (San Diego, CA)

1992

ABA Tax Section Meeting, Real Estate Taxation – Troubled Real Estate (San Francisco, CA)

ABA Tax Section Annual Meeting, Loan Restructuring (San Francisco, CA)

1991

Ali/ABA, Creative Tax Planning for Real Estate in a Depressed Market (Washington, DC)

ABA Tax Section May Meting, Foreign Investment in U.S (Washington, DC)

NY Accounting Lawyers Assn., Tax Consideration in Bankruptcy (New York, NY)

1990

ABA Annual Meeting, Proposed Changes to Capital Gains Taxation of Foreigners (Chicago, IL)

ABA Tax Section Meeting, Tax Reporting for Foreign Owned U.S. Corporations (Washington, DC)