13+ years of international and transactional tax experience
Focuses on international tax planning and structuring as well as transactional tax matters
New York
@alvarezmarsal
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Alon Kritzman is a Senior Director with Alvarez & Marsal’s Tax in New York. He focuses on international tax planning and structuring as well as transactional tax matters.
With more than 13 years of international and transactional tax experience, Mr. Kritzman advises multinational organizations on complex international and domestic corporate tax matters including international tax (foreign tax credit and repatriation) planning, global supply chain and IP planning, cross border (inbound and outbound) M&A and financing, internal restructurings, and international tax compliance and provision.
Prior to joining A&M, Mr. Kritzman was a Senior Manager in the international tax services practice at Ernst & Young in New York. He provided advisory services (including tax due diligence, tax modeling and structuring) to strategic corporate clients, focusing on the industrial conglomerates and big pharma space. Previously, he served as an attorney at McDermott Will & Emery LLP in Chicago.
Mr. Kritzman earned a bachelor’s degree in accounting from the Tel Aviv University School of Management, an LL.B from the Tel Aviv University Buchmann Faculty of Law, and a master’s in taxation (with honors) from Northwestern University. He is admitted to practice law in New York and in Israel.
On August 6, 2024, Treasury and the IRS released proposed regulations that address several long-standing issues related to dual consolidated losses and introduce new rules for disregarded payment losses. What are the impacts that taxpayers should consider?
On June 20, 2024, the U.S. Supreme Court ruled that the TCJA section 965 transition tax imposed on certain U.S. shareholders is constitutional in Moore v. United States. In this alert, we focus on the broader legacy that Moore may leave as businesses and individuals consider the implications of the Court’s analysis and decision.
On November 9, 2023, in a seemingly endless effort to address a daunting responsibility delegated to them back in 1986, Treasury and the IRS released a new set of proposed regulations (REG-132422-17) for determining taxable income or loss and foreign currency gain or loss with respect to a “qualified business unit” (QBU) with a different functional currency (FC) from that of its owner.
The government’s recent win on a motion for summary judgment against Liberty Global Inc. could further embolden the IRS’s use of a long-standing doctrine in pursuit of tax avoidance transactions.
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