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BRUCE ZAGARIS
Berliner Corcoran & Rowe
L.L.P, Washington DC.
Bruce Zagaris has a
B.A., J.D., and LL.M. from The George Washington University.
His B.A. included a major in international affairs with a
specialty in Latin American Affairs. After serving as a law
clerk for the U.S. District Court for the Southern District of
West Virginia (1972-73), Mr. Zagaris was an Assistant Attorney
General for the State of Idaho (1973-74). Mr. Zagaris received
graduate legal diplomas from Stockholm University, Sweden
(1975) and from the Free University, Brussels (1976). While in
Scandinavia, Mr. Zagaris did research as a result of Swedish
and Finnish government sponsored scholarships. His research
resulted in three articles that were published and are noted
below.
During his two years in
Europe, in 1974-76, Mr. Zagaris worked for the Nordic Law
Consultants and served as a UN consultant to the Mano River
Union, a customs union in West Africa. At the Free
University's Program on International Legal Cooperation
(PILC), Mr. Zagaris took international criminal law from Bart
deSchutter. In 1976-77, Mr. Zagaris was in private practice
with Glad, Tuttle & White in San Francisco. In 1977-78, he
was a lecturer at the Faculty of Law, University of the West
Indies, Barbados, teaching comparative law, public
international law, and international tax law.
Mr. Zagaris was an
Adjunct Professor for six years at the Washington College of
Law, American University in Washington, and at the Fordham
University Law School in New York, where he taught
international business criminal law. He has also been an
Adjunct Professor at John Marshall College in Chicago and the
University of Montana School of Law.
Since November 1978, Mr.
Zagaris has practiced law in Washington, DC, where he is a
partner with Berliner Corcoran & Rowe, LLP. He has served
as a consultant, counsel and lobbyist for fourteen governments
on various subjects.
International
Criminal Law Work
He has served as counsel
in more than forty criminal trials and approximately five
appellate cases. In addition, he has handled evidence
gathering and extradition cases both on the interstate and
international levels and cases involving prisoner transfer
applications. His criminal work has included counseling on
extradition and international evidence gathering cases,
testifying as an expert in international criminal cases
involving money laundering and tax crimes, counseling of
witnesses for grand jury investigations, prisoner rights,
representation of parolees, probation revocation matters, and
early release of prisoners on emergency medical problems. His
private practice has also included monitoring international
tax and enforcement developments in the U.S. and the Caribbean
for foreign governments and corporate clients. Since 1985, he
has edited the International Enforcement Law Reporter, a
monthly publication which discusses developments in
international criminal and related enforcement law matters.
Some of Mr. Zagaris'
international enforcement work has involved counseling the
private sector on prevention strategies. He has counseled a
Latin American bank with an offshore mutual fund in complying
with anti-money laundering requirements in the custodian's
country. He has counseled an international trust company on
the development of due diligence procedures to safeguard
against money laundering and financial fraud. He has counseled
corporations on compliance with transnational corruption laws.
Mr. Zagaris has served
as an expert witness and/or consultant on several occasions.
During 1992-93, he served as a consultant and expert witness
on a money laundering case concerning video poker. In the
1990s, he served as a consultant in the case of Robert Doorn,
a Dutch businessman charged in several U.S. district court
cases with money laundering and securities-related crimes. In
1992, he prepared a study for the Police Executive Research
Forum (PERF) on how 9 countries in 3 regions are complying
with international money laundering laws. On May 10, 1993, he
served as an expert witness in a case involving discharge of
an auditor for a broker-dealer in the aftermath of his report
on alleged abuses. Also in 1993, Mr. Zagaris prepared a study
for the PERF on how international law can combat Colombian
organized crime groups. In 1995-96, Mr. Zagaris served as an
expert witness in three money laundering cases in U.S.
District Courts, two in the Middle District of Florida (Tampa
and Ft. Myers) and one in Tucson. His role in U.S. v. Leyton
et al, U.S. District Court M.D. Florida, Tampa, No.
94-41-CR-T-25E, helped in a not guilty verdict for all
defendants and is discussed in Federal Jury in Fla. Rejects
DEA Money Laundering Sting, BNA Criminal Practical Manual 451
(1995). His testimony in United States v. Andre Brady, U.S.
District Court Middle District of Florida, Ft. Myers Div.,
Case No. 95-90-CR-RTM-22, helped in ultimately dismissing the
case after a hung jury. In 1995, his affidavit in an
international tax case was cited by the 9th Circuit in the
case of In re Marsoner, 40 F.3d 959 (9th Cir. 1994). Also, in
1995, his testimony as an expert witness in the case of Joseph
Muldrow v. Donaldson Lufkin & Jenrette, an arbitration
before an arbitral panel of the New York Stock Exchange,
involving the discharge of an auditor for reporting various
violations of anti-money laundering laws on international
transfer of funds in DLJ’s Miami office, resulted in a
verdict in favor of the auditor for whom he testified. CNBC
subsequently did a piece on it, in which Mr. Zagaris was
featured. In 1997, his testimony for the U.S. Government
helped convict the defendant in U.S. v. David Harris, U.S.
District Court, E.D.Mo., 96CR0057CAS. He has worked as an
expert witness and consultant on several white collar cases
that were settled. In 1997, the U.S. Department of Justice
retained Mr. Zagaris in a case in the U.S. Dist. Ct.,
Colorado, involving an international tax matter and offshore
issues. In 1998, he provided advice in the extradition of In
The Matter of the Extradition of David Cybulkiewicz (by the
U.S. from Aruba). In September 1998 to December 1998, he
served as a consultant to defense counsel in the case of
United States v. Peter Post, U.S. District Court for the
District of New Hampshire, Docket No. 98-57-01-JD, on the
issue of a transfer of prisoner application. In 1999, the
defendants in U.S. v. Nanne Hogendoorn, U.S. Dist. Ct., Alaska
[No. A98-0087CR (JKS)] hired him as a consult and expert
witness in evidence gathering arising out of charges
concerning ocean waste discharges. Defendants were successful
in obtaining an order allowing them to use the U.S. MLAT for
evidence gathering. In 2000, he worked as a consultant for the
defense In The Matter of the Extradition of Pavel Lazarenko,
the former prime minister of the Ukraine, in the U.S. District
Court, N.D.Ca., and in connection with the Antiguan asset
forfeiture case. In 2000, he served as a consultant for the
defense in U.S. v. Riley Hill, U.S. District Court, D.Ore., a
criminal tax case involving offshore jurisdictions. In 2001,
he worked as a consultant and gave expert testimony for the
defense in the extradition of Gerard P. Hoogendijk in The
Netherlands. In 2001, he worked as counsel for the applicant
and successfully won a motion of reconsideration on the
application of U.S. v. Jannes Doppenberg, Case No. 95-CR-221,
to transfer to The Netherlands, and represented him at the
Verification Consent Hearing in the U.S. District Court,
W.D.Wis. In 2001, he served as an expert witness in the case
of U.S. v. Mejia et al. [Homes Valencio-Rios], U.S. Distr.
Court for D.C. , No. 99-389, where he was qualified as an
expert on international criminal law, international narcotics
control, and transportation of cocaine. In 2001, he served as
a consultant to a former minister of a Central Asian country
charged with corruption in his former country.
Some of the cases for
which Mr. Zagaris was retained were settled. In 1995, he was
retained as an expert in the case of Golden Discovery, S.A. v.
Oppenheimer & Co., Inc. et al, an arbitration before an
arbitral panel of the New York Stock Exchange involving
international transfers of money by a securities broker and
issues of Panamanian company law. He was retained by
taxpayer’s counsel in a criminal tax case with offshore
pension fund issues in the U.S. District Court in Phoenix that
was disposed of on the day of trial in 1995. He was retained
by defense counsel in a money laundering case involving BCCI
in U.S. District, Tampa, Florida, that resulted in a plea. In
1996-97, Mr. Zagaris represented Jim and Penny Fletcher in a
murder case in St. Vincent, in which the charges against both
were dismissed at trial. Since 1996, Mr. Zagaris has
represented David M. Duchow in an embezzlement charge in
Bolivia, bringing a civil action on Freedom of Information Act
request in the U.S. District Court in D.C. and serving as an
expert in the criminal case. The Bolivian trial court cited
his expert affidavit in its dismissal of the case for lack of
jurisdiction due to diplomatic immunity.
The dissenting opinion
in United States v. Aloyzas Balsys, No. 97-873, 1998 U.S.
Lexis 4210, at *1 (U.S. Supreme Court, June 25, 1998) refers
to one of Mr. Zagaris’ law review articles.
Mr. Zagaris has handled
transfer of prisoner applications and advised accused and
convicted persons of the operation of these treaties and the
pros and cons of applying under them.
Mr. Zagaris has been
active in civil prosecution on behalf of victims of
transnational crimes and torts. In 1979, Mr. Zagaris was sole
counsel on behalf of Gloria Banks against members of the Saudi
royal family in an action in U.S. District Court for damages
arising from false imprisonment, assault and battery and civil
rights infringements while she was a nanny in Saudi Arabia.
The case, which was discussed in the international media,
resulted in a substantial recovery. Mr. Zagaris helped achieve
a substantial recovery from a branch of the Reichman family in
a civil fraud, RICO action in the S.D.N.Y. arising from a
fraud by a person allegedly soliciting money for a non-profit
organization from a French non-profit affiliated with the
Reichman family. The case involved the use of criminal and
civil prosecution simultaneously. Mr. Zagaris is co-counsel in
Kenneth Walker et al v. U.S., Case No. 12.049 in the
Inter-American Commission on Human Rights, concerning
abduction by fraud (or luring as an alternative to
extradition). On March 5, 1999, the Commission convened a
hearing. In 1996-97, Mr. Zagaris helped advise plaintiff
Segovia in a case seeking equitable relief in New York state
court for “an advanced fee fraud scheme” against a
Nigerian bank, in which the court froze on a pre-trial basis
the bank’s assets. In 2002-3, Mr. Zagaris served as an
expert in Gerdy Hnry-Pfeiffer v. Barry Walter Henry, U.S.
Dist. Ct., S.D.Fla., Case. No.: 02-80554-CIV.-Middlebrooks, in
which the plaintiff successfully obtained an order for letters
rogatory to obtain documents in support of her divorce decree
in Monaco and her effort to uncover assets.
At the request of the
House Ways & Means Oversight Committee, Mr. Zagaris
testified on the tax information exchange provisions and
agreements under the Caribbean Basin Economic Recovery Act in
February 1986. In September 1987, he testified at the request
of the Subcommittee on Commerce, Consumer and Monetary
Affairs, Committee on Government Operations, on the U.S.
Government's efforts to combat international tax evasion. In
September 1988, at the request of the Senate Foreign Relations
Committee, he testified on whether the U.S. should ratify six
pending Mutual Legal Assistance Treaties. In December 1999, at
the request of the Commission, he testified before the
National Gambling Impact Study Commission.
On April 19, 1996, Mr.
Zagaris advised the National Security Council on strategy for
dealing with international organized crime. On September 23,
1996, he participate in an open forum at the Department of
State on the transnational criminal international
organizations. In 1985-86, as a consultant to the U.S. Agency
for International Assistance (USAID), he helped prepare a
project paper for the Caribbean Justice Improvement Project.
On several occasions, he has served as a speaker for the U.S.
Information Agency in other countries, including Mexico,
Chile, the Czech Republic, Nigeria, and Portugal, and on
satellite television programs on money laundering,
international tax enforcement, and financial investigations.
Periodically, Mr. Zagaris has consulted for the State
Department on requests by foreign governments for technical
and financial assistance on administration of justice
projects. In 1996, he advised the National Security Council of
initiatives against transnational organized crime. Since 1995,
he has lectured for the Foreign Service Institute to U.S.
diplomats appointed to Mexico on U.S.-Mexico law enforcement
issues.
Mr. Zagaris has worked
with a number of international organizations on crime
prevention matters, including the U.N. Crime Branch, the
International Monetary Fund, the World Bank, the Asian
Development Bank, and the Caribbean Financial Action Task
Force.
Among the books for
which he is author and/or editor are Developments in
Mexican-U.S. Law Enforcement Cooperation: What the
Practitioner Needs to Know (198 pp., Crim. Just. Sec., ABA,
April 20, 1989); along with Dr. Scott MacDonald, Mr. Zagaris
is the editor of the International Handbook on Drug Control
(463 pp. Greenwood Press 1992); along with Jordan Paust et al,
he is editor of International Criminal Law: Cases &
Materials (Carolina Academic Press, 2d edition 2000); he is
co-chairman of International Exchange of Tax Information:
Recent Developments (PLI, 1985, F4-3566). He has also written
hundreds of law review and other articles.
Mr. Zagaris was
co-chairperson for the ALI-ABA program on International
Criminal Law in 1982. During 1987-90, he was Chair, Committee
on Criminal Law and Procedure, Inter-American Bar Association.
During June 1989-93, he was founder and Chair of the Committee
on International Criminal Law, Section of Criminal Justice
American Bar Association. He is a board member, U.S. branch,
of the International Penal Law Association (AIDP), and has
participated in programs of its subsidiary, the International
Institute for the Studies of Higher Criminal Sciences in
Siracusa, Sicily. He serves as the representative of the AIDP
to the Organization of American States (OAS). He is also a
member of the American Society of International Law (ASIL) and
its International Criminal Law Interest Group. Since 1997, he
has served as Vice-Chair, Committee 6 (criminal law),
International Bar Association. Since 1996, he has served as
Chair and Co-Chair, Committee on International Criminal and
National Security Law, Section of International Law, District
of Columbia Bar. Since 1999, he has served on the Criminal
Justice Advisory Board of Lexis-Nexis. In 1972-73, he helped
form a self-help statewide prison organization in West
Virginia. In 1973-74, he was a board member of a self-help
statewide prison organization in Idaho.
International Tax
Work - Private Sector/Transactional
Mr. Zagaris' practice
includes structuring international business transactions and
especially international tax aspects.
The transactional
aspects of the international tax work has included planning a
variety of investments and trade by foreign persons into the
U.S. This work included structuring a variety of investments
into U.S. real estate, including commercial real estate, such
as office buildings, shopping centers, apartment buildings,
and agricultural land. In addition to planning the tax
consequences, this work included advice on reporting and
regulatory aspects, such as complying with the Agricultural
Foreign Investment Disclosure Act and the Bureau of Economic
Analysis reports. In connection with reporting requirements,
Mr. Zagaris has served as a consultant for other law firms and
their clients.
The inbound investment
work has included providing advice on transactions involving
trading and/or direct investment into the U.S., including
advice on proposed structures, potential application of U.S.
tax laws to "doing business in the U.S.,"
alternative treaty structures, and withholding requirements.
Mr. Zagaris has advised
individuals and entities on the application of U.S. tax laws
to various investments in bank deposit and other instruments
(e.g., money market funds, bonds, and insurance accounts). He
has advised foreign entities on lending to U.S. persons and
the portfolio interest rules.
For a foreign fiduciary,
Mr. Zagaris has advised on the taxation of death benefits
received by the estate.
The structuring of
transactions for foreigners has included several Latin
American and Caribbean non-profit organizations, who have
started U.S. corporations and obtained exempt status. The work
has involved business planning, corporate work, filing and
obtaining rulings from the IRS, implementation of business
plans, serving on the board of directors in some cases,
attending meetings, and advising on certain transactions and
reorganizations.
Mr. Zagaris has advised
many individuals on whether they are classified as a U.S.
taxpayer and therefore have reporting and other federal and
state income tax requirements. One classification case was
litigated before the U.S. Tax Court. His work included a
project with the American Bar Association's Coordinating
Committee on Immigration concerning federal and state tax
responsibilities of aliens eligible for the amnesty program.
His work has also
included various tax compliance and controversy work. This has
involved advice on complying with reporting requirements under
Sections 6038A and C of the Internal Revenue Code, and
advising on audits concerning transfer pricing. In particular,
the work included advising several foreign corporations on
proposed structures and transactions with the U.S. The work
has included handling the administrative and civil litigation
concerning jeopardy assessments involving dual nationals. He
has represented taxpayers in preparing and negotiating offers
in compromise with the IRS.
Mr. Zagaris has advised
and handled international business transactions for U.S.
taxpayers. The work has included advice on qualification for
and implementation of qualification as a foreign sales
corporation and the tax benefits attributed thereto. His
transactional work has included advising clients on the
application of Subpart F to proposed structures and planning
joint ventures. The work has required him to negotiate joint
venture agreements abroad and advise on the interaction
between foreign and U.S. tax and business laws. He has helped
with arranging financing through the private sources and U.S.
government agencies, such as the Overseas Private Investment
Corporation. His work has included preparing licensing,
distribution, and agency agreements. His work has involved
advising on captive insurance transactions. The insurance work
has involved substantial lobbying concerning the efforts in
the U.S. Congress to raise the excise tax on certain foreign
reinsurance transactions, the Risk Retention Act, and other
regulatory efforts impacting international insurance. His
insurance work has included reviewing insurance contracts for
clients, such as financial institutions, and suggesting
changes of proposed policies. The specialized nature of this
work has resulted in his attending and arranging programs
during the annual Risk Insurance Management Society (RIMS)
meetings. Mr. Zagaris was a negotiator for the Government of
Barbados in its 1983 tax treaty with the U.S., which provided
for an exemption on excise tax for certain insurance
transactions. This led to work for American companies wanting
to establish captive companies in Barbados.
Mr. Zagaris has advised
individual U.S. taxpayers. Several taxpayers have received his
advice on the issue of expatriation. This advice has included
not only tax, but the potential application of immigration and
criminal laws. In one case he persuaded taxpayers who had
departed the U.S. and were living abroad in the implementation
of an expatriation plan during a bankruptcy proceeding to
return to the U.S. and restore the proceeds to the bankruptcy
court. Mr. Zagaris has advised U.S. taxpayers, including
permanent residents, of the laws and pros and cons of
expatriating.
Mr. Zagaris has advised
numerous individuals who have worked for the U.S. Government,
often in the foreign service, and international organizations.
The advice has included: taxability of income; potential
roll-over of their residence, especially when they return from
overseas; their potential taxability in various states and
their selection of states as their domicile; and their
potential liability for taxes on state and local levels. He
has advised foreign governments on planning transactions, both
in connection with tax and non-tax liability (e.g.,
applicability of sovereign immunity when bank accounts mix
commercial and non-commercial sources of funds). Mr. Zagaris
has helped implement the advice.
Mr. Zagaris has advised
on establishing offshore protection of assets trust and
various alternate mechanisms.
In advising high net
worth individuals, Mr. Zagaris has given international estate
planning advice and helped implement the same through
preparing wills, trusts, powers of attorneys, and related
documents. Mr. Zagaris has handled probates, both in primary
and ancillary capacities. He has represented parties in
contested probate proceedings and outside of formal
proceedings. He has advised on efforts to contest estate
plans.
Mr. Zagaris has
participated extensively in cases involving the interaction
between international transactions and the enforcement aspects
of international money movement, including advising and
planning transactions to comply with the law, helping in
devising prevention plans, teaching and training law
enforcement officials, testifying as an expert witness,
consulting for counsel involved in litigation, and
professionals engaged in transactions who request advice.
Because of the extensive and specialized nature of this work,
it is summarized on a document called "background for
international money movement work."
International Tax
Work - Public Sector
Since 1981 Mr. Zagaris
has regularly represented the Government of Barbados. From
1985-87, he represented the Government of Belize. Much of the
Barbados work has included advising and negotiating on tax
treaties and strategy and legislation related to the offshore
sector. For these two governments Mr. Zagaris was a registered
agent. For developing governments Mr. Zagaris has advised on
obtaining tax administration assistance. In 1991 he organized
and moderated a program on tax administration assistance
sponsored by the International Law Institute, Washington, D.C.
Mr. Zagaris was co-chair of International Exchange of Tax
Information Recent Developments (Practicing Law Institute,
1985).
Since 1986 he has spoken
at each of the international tax institutes of the Florida Bar
and Certified Public Accountants.
He is a frequent speaker at programs of the Practicing Law
Institute, American Law Institute-American Bar Association,
World Trade Center, and showcase programs at the American Bar
Association's Annual Conventions on international taxation.
Since 1979-86, he served as U.S. editor for Taxes
International, a monthly publication. He helped found and has
regularly spoken at programs of the Barbados branch of the
International Fiscal Association. He has spoken at the first
two Caribbean conferences of the International Tax Academy (in
Aruba, 1993, and Cancun, 1994). He spoke at the Caribbean
Conference of the Offshore Investment Journal in San Juan. He
has spoken on gathering evidence under tax information
exchange agreements, compulsory and other means in connection
with transfer pricing programs. These programs have included
the following: a Program on Section 6038A by the Institute for
International Research on September 26-27, 1993; and programs
on Transfer Pricing held by the American Conference Institute
(ACI) in New York City on November 8, 1993 and by the Canadian
Institute in Toronto on February 21-22, 1994 and Chicago on
March 3-4, 1994. On November 15, 1994, he spoke on the U.S.
Model Income Tax Treaty at the ACI program on Income Tax
Treaties in New York City. On January 29, 1994, at the ABA Tax
Section winter meeting in Houston he organized and moderated a
program on the long arm of the taxman and international tax
enforcement issues.
On March 23-28, 1992, Mr. Zagaris was an AMPART speaker for
the U.S. Information Agency during a visit to four cities in
Mexico, speaking in Spanish to business groups on the
international tax aspects of free trade with the U.S. In 1993
he consulted for and prepared a paper for the Caribbean Law
Institute on tax treaty options for the Commonwealth
Caribbean. Mr. Zagaris has participated in programs on the
international tax and business aspects of transnational
philanthropy. He participated in and wrote a paper for a
program in April 1992 sponsored by the Smithsonian Institute
and non-governmental organizations on the tax and accounting
aspects of debt forgiveness in the Enterprise for Americas
Initiative. He has organized and moderated a speech given by
Dr. Trevor Carmichael and sponsored by the Committee on
International Taxation on the Use of Barbados as a Center for
Non-Profit Organizations, which was held in New York City. He
has helped organize two chapters for a book on transnational
philanthropy, which Martinus Nijhoff is publishing.
At the request of the
House Ways & Means oversight Subcommittee, Mr. Zagaris
testified in February, 1986, on the tax information exchange
agreements under the Caribbean Basin Economic Recovery Act. At
the request of the Subcommittee on Commerce, Consumer and
Monetary Affairs, Committee on Government operations, he
testified on September 16, 1987 on the state of the U.S.
Government's efforts to combat international tax evasion,
particularly focusing on treaty arrangements in the Caribbean,
multilateral cooperation, and bilateral relations with the
Netherlands Antilles in the wake of the partial cancellation
by the U.S. of its tax treaty with the Antilles. In 1993, he
testified on behalf of the Government of Barbados before the
House Ways & Means Committee on HR 5271 (the Foreign
Simplification and Rationalization Tax Act).
He has represented
individuals and entities in tax litigation in both the civil
and criminal aspects and is a member of the U.S. Tax Court.
Mr. Zagaris taught courses on international tax law at
universities, including the law faculty of the University of
the West Indies. During 1990-92 he was Chair, Committee on
International Tax Law, Section of International Law and
Practice, American Bar Association; and Chair of the
International Tax and Comparative Law Subcommittee, Committee
on International Property Trust & Estates Committee,
Section of International Law, ABA. Since 1993, he has served
as chair, subcommittee on international, Civil and Criminal
Penalties, Tax Section, ABA. He is a member of the Section of
Taxation, ABA, and the International Fiscal Association. He is
Caribbean editor, International Bulletin for Fiscal
Documentation.
In 1979, he authored
Foreign Investment in the United States (Praeger Press, 323
pp.). In 1978, he edited Handbook -- Materials for
International Tax Law (Faculty of Law and Extramural
Department, University of the West Indies 1978, 351 pp., 2
vols.).
He has authored various
major articles on international tax law. Some of them include:
Protectionism or Opening Foreign Markets to U.S. Reinsurance
Industry, 7 The Insurance Tax Rev. 92934 (September
1993)(co-author); Double Taxation Agreements of CARICOM: A
Review of Existing Practice and Prospective Policy Options,
Bull. International Fiscal Doc. 129-42 (Mar. 1993); Tax
Collection Assistance and Evidence Gathering, The New
U.S.-Netherlands Tax Convention, 121-36 (Feb. 9, 1993,
International Tax Academy); Insights on International Tax Law,
26 International Lawyer 297--302 (1992); Financing and
Technology Transfer: Environmental Protection Through
Multilateral Development Banks and Other Alternatives,
International Environmental Law 59 pp. (National Institute,
ABA 1991); The Bahamas Adds New Infrastructure and A Series of
New Products, Bull. for International Fiscal Doc. 479 (Oct.
1991); Taxation of Foreign Governments and International
Organizations, Bender's Federal Tax Service (co-author),
Chapter M:41-13 (Matthew Bender 1989); The Caribbean Basin Tax
Information Exchange Agreements Program of the U.S.: Eat
Softly and Carry a Big Stick, Bull for International Fiscal
Doc. 115 (March 1989); The Legal Environment for International
Investment in Belize, U.S. Taxation of International
Operations 9011-9024 (Prentice Hall Info. Serv. 1989);
Financing Participation in Caribbean Basin Investments and
Trade, 17 Inter-American Law Review 97-130 (1985); Treaty
Changes Affecting Personal Income, The New Canada-U.S. Income
Tax Treaty 373-414 (PLI 1984); Investment by Non-Resident
Aliens in U.S. Real Estate, 31 University of Miami Law Review
566-614 (Spring 1977); Characterization of the Anstalt, the
Stiftung, and Other Unusual Entities, Foreign Tax Planning
1981 725-40 (PLI 1981); Personal Services Income, Income Tax
Treaties, 28 pp. (ALI-ABA March, 1981 ); Personal Services
Income, Income Tax Treaties 106-54 (ALI-ABA, September 30,
1992); Barbados Develops as a Low Tax Jurisdiction, 15
International Lawyer 673-85 (Fall 1981); The Rising Utility of
the Public international Corporation, 6 Denver J.
International Law & Policy 43-81 (Spring 1976); The
Agricultural Foreign Investment Disclosure Act of 1978: The
First Regulation of Foreign Investment in United States Real
Estate, U.S.D.A. Working paper Series, 27 pp., November, 1979,
reprinted in Foreign Tax Planning 1979, 67-96 (PLI);
Intergovernmental Exchange of Foreign Investment Information,
2 Monitoring Foreign Ownership of U.S. Real Estate, 189-224
(U.S.D.A. 1979); Foreign Country Regulations and Activities, 1
Monitoring Foreign Ownership of U.S. Real Estate 117-329
(U.S.D.A. 1979).
Mr. Zagaris has written
a number of articles on Barbados tax and financial services,
including the chapter in Tax Havens Encyclopaedia (70 pp. with
annual updates, Spitz, ed., Butterworths & Co.);
Application of the Lom‚ IV Convention to Services and the
Potential Opportunities for the Barbados International
Financial Sector, Bulletin for International Fiscal
Documentation 289-303 (June 1991); New Barbados Treaties Add
Wind for Its Sails 17 Offshore Investment 23-30 (January
1991); New Opportunities for U.S. Persons Engaged in Foreign
Shipping to Use Barbados (co-author), U.S. Taxation of
International Operations 9175-82 (Prentice Hall, 1989) Income
and Capital Taxation of Individuals, and Corporation Law, in
Spitz (ed.), Thesaurus of World Tax Data; Barbados: A Base for
International Operations and Investment, U.S. Taxation of
International Operations Service 8771-86 (Prentice-Hall 1985);
Barbados Develops as a Low Tax Jurisdiction, 15 International
Lawyer 673-86 (1981).
Mr. Zagaris has written
over 70 smaller articles (e.g., 1 to 5 pages) and book reviews
on international tax for journals, such as Taxes
International, Tax Notes International, Tax Planning
International, and the American Journal of International Law.
Mr. Zagaris has written
op-ed pieces on transactional and policy aspects of
international tax, such as: International Tax Outlaw,
Washington Post, November 7, 1989, A25, col. 4 (about the
adverse impact of proposed tax treatment of foreign investors
into the U.S.); and "Fat Tax": No Cure for a Thin
Wallet, Washington Post, March 13, 1990, B, col. 4 (critique
of proposed professional services tax of D.C. Government).
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