Stanley C. Ruchelman
Chairman
E. ruchelman@ruchelaw.com
T. 212.755.3333 x 111
Practice
Whether it is a sophisticated corporate restructuring, individual tax, or multinational compliance matter, Stanley is a significant value-add to any project. He brings humor, ethics, and cross-border business experience to the table to craft workable solutions to his clients’ most complex issues.
In the course of his career, Stanley has worked across industries and borders:
For a non-U.S. shipping client under I.R.S. examination, he successfully demonstrated that revenue from the transportation of cargo and personnel between the U.S. and a specific point in the South Pacific qualified as international shipping income that was eligible for a complete tax exemption in the U.S.
When a major broadcast network was advised by a foreign tax authority that the temporary importation and use of broadcast equipment to cover the Olympic Games would result in a permanent establishment, Stanley formulated the strategy used by the network to successfully defend against risk of foreign income tax, saving the company tens of millions of dollars.
A non-U.S. HNW individual was part owner of a French societe civile scheduled to receive a royalty payment from a licensee in the U.S. Many questions were raised about U.S. withholding tax. In conjunction with tax advisers in other jurisdictions, Stanley fashioned a global plan by which the royalty was paid free of U.S. withholding tax. Although French tax at 16% was imposed on the client, no further Swiss tax was due, even though Swiss tax was generally imposed on worldwide income.
Stanley began his career as an Attorney Adviser to the Honorable Charles R. Simpson, Judge of the U.S. Tax Court. After that, he participated in negotiating income tax treaties and developing legislative and regulatory policy affecting international business as a Senior Attorney in the I.R.S. Office of Chief Counsel. Before founding Ruchelman P.L.L.C., Stanley was an international tax partner at one of the major international accounting firms. There, he spent eight years advising on cross-border tax matters.
Qualifications
Education
J.D. — George Washington University
B.A. — Brooklyn College
Bar Admissions
New York
District of Columbia
Languages
English
Affiliations
Current
Co-Chair — International Section Committee on International Tax, New York State Bar Association
Member of the Steering Committee — International Tax Specialist Group (ITSG)
American Bar Foundation
American College of Tax Counsel
Past
Adjunct Professor — New York Law School, Tax LL.M Program
Chair — Committee on U.S. Activities of Foreigners and Tax Treaties, A.B.A. Section of Taxation
Chair — International Tax Committee, A.B.A. Section of International Law and Practice
Council Member — International Fiscal Association, U.S.A. Branch