A lot of things happened in 1980. In
the ’70s, foreign firms and New York firms
could not operate in California under their
name because all [name partners] had
to be members of the California State
Bar. That changed by a state Supreme
Court decision in about 1976, if I recall.
All of a sudden, California looked like
an interesting place to set up a branch
operation and a lot of the East Coast
firms started doing that. By 1980, our
little tax group became of interest. So we
reluctantly abandoned our boutique and
joined some big firms. I was with Bryan
Cave for about 10 years. Then I basically
went out on my own.
Q: What’s the focus of your practice
A: Most of the practice is still tax. We do a
huge amount of regulatory work. We have
people who are referred to us because they
decided it was time to reveal their foreign
bank accounts. Or they were still partners
in the family farm in New Zealand after
they immigrated to the United States, and
all of these people suddenly discovered
they had to disclose this and file amended
returns. So we’ve been doing a lot of
compliance work since 2009.
Q: What happened in 2009?
A: That’s when they had the first Offshore
Voluntary Disclosure Program. It’s gotten
tougher and more complicated since.
Q: Was this a post-9/11 change?
A: You know what I think it’s related to?
The government suddenly decided they
needed more revenue. It’s been on the
books for a while, but nobody had been
enforcing it. So they gave it a brief try and
it shocked the Treasury Department how
much money they took in. Of course, then
they actually found and prosecuted some
really bad guys who had formed some
Q: So are most of your clients foreign-born
Q: How do you keep up with changes in
citizens? Are they American citizens?
A: We do a lot of work with Americans
who are being transferred abroad, [or]
who have offshore businesses. I work
with some interesting young people who
decided that China is the next wave, and
so they set up operations in China. They’re
getting Chinese clients to do EB- 5 visas
and invest heavily in the United States.
international tax law?
A: I spend about an hour or two every
morning going online to see what the
government has done to us today. If you
don’t do that, you’d be surprised how
quickly things pile up.
Q: You’ve been doing this for more
than half a century. How much more
complicated has the tax code gotten?
A: When I started law school, the Revenue
Act of 1954 had just been passed. It was one
volume and a little over an inch thick. There
was one volume of regulations about maybe
an inch and a half thick. That was it. Now, we
have two really thick volumes of code, each
one maybe two inches thick. And we’ve got
six volumes of regulations, also on average
about two inches thick. And if Congress
didn’t do a thing to the code for the next
25 years, Treasury couldn’t catch up on all
the regulations they have yet to write with
respect to the laws that have been passed.
Q: Why so many changes?
A: People with an axe to grind will study
the regulations and look for loopholes
and then they’ll test those loopholes.
Eventually, a revenue agent will come
upon that loophole and say, “What the
hell are you doing?” And they say, “Well,
it’s not covered by the regs.” And they’ll
look up the regs and say, “Damn, they’re
right. How can we close this?” And if they
can’t find a way to plug it up, then they’ll
go back and change the regs or they’ll
get the chief counsel to come up with an
interpretive release which purports to close
the loophole while they’re trying to write
new regs. So it’s a cat and mouse game, a
constantly changing field.
Q: Why law? What did your father do?
A: My father was an engineer. He would
have shot me if I had become an engineer.
Q: Because he didn’t enjoy it?
A: He loved being an engineer. But he
graduated in 1929.
Q: Bad time to graduate.
A: Who wanted engineers? The only job
he could get was with the Army Corps of
Engineers. He was a chemical engineer
and he was building roads and bridges
across the Rocky Mountains.
Q: So what made you choose the law?
A: Well, my debate partner and I were
national champions one year.
Q: High school?
A: Junior college. Neither of us was
wealthy enough to even aspire to a four-
year college at that point. This was, I
think, in 1952.
One of the judges from the final round
was Coach Nichols of the USC debate
squad, and he offered us scholarships to
come and debate for him at USC. In those
days, there was no television, and we
didn’t know all that much about big-time
football. We thought that the University
of Southern California was the southern
campus of the University of California.
That’s how much we knew.
When we came out here on Route
66—there were no freeways—we found
ourselves in downtown LA. We saw a
gentleman in a suit on the corner. “Excuse
us, can you tell us how to get to the
university?” He said, “Which one?” I said,
“How many are there?” He said, “Five or
six.” We were absolutely dumbfounded.
Neither of us could think of the actual
name of the university, and we said, “Oh
it’s the southern campus of the University
of California.” So we ended up at UCLA
and found the administration building,
gave them our papers. The fellow looked
at the papers and he said, “Boys, it’s the
right day, it’s the right city, but it’s the
When we finally found USC and found
the administration building, it was after
5 and it was closed. The next morning we
went in to register and the person behind
the desk said, “You boys were supposed
to be here yesterday. What happened?”
And we told him. He excused himself for
a minute, went into a back room. A few
minutes later we heard some laughter
from the back room and he came back out
and said, “We’re going to hold registration
open for you today.”