Marcum LLP

Douglas Nakajima


J.D., LL.M
 
Douglas  Nakajima, International Tax Co-Leader, Tax & Business
International Tax Co-Leader
Tax & Business
 

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Philadelphia, PA 19103

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Douglas Nakajima is co-leader of Marcum’s International Tax Services Practice and a director in the Firm’s Tax & Business Services Division.

Mr. Nakajima has over 30 years of experience in federal and international tax and strategic business planning, advising a diverse client base of U.S. and multinational manufacturing, service and technology and financial services businesses. He has advised public and private clients on the tax treatment of domestic and cross-border transactions, inbound and outbound business expansion strategies, domestic and cross-border acquisitions, dispositions and reorganizations, intercompany transfer pricing, treaty interpretation, and repatriation planning. He has worked extensively with tax advisors in foreign countries to develop global structures that minimized U.S. and foreign tax exposures, and in this role, has forged effective working relationships with key professionals throughout North America, Europe, Asia and the Pacific Rim.

Mr. Nakajima’s previous experience includes tax leadership positions with international, national and regional accounting firms. He also served as tax counsel to a Fortune 100 corporation, where he was responsible for the restructuring of the company following its acquisition of a foreign-owned U.S. competitor. Mr. Nakajima is an attorney admitted to practice in Pennsylvania.

Professional & Civic Affiliations
  • White Horse Village, Inc., Board of Directors
  • Philadelphia Tax Conference, Inc., Board of Directors
  • IGAF Worldwide, North America, Board of Directors (Former)
Articles, Seminars & Presentations
  • Chicago Tax Club
  • IGAF Worldwide North American and European Group Tax Conferences
  • Leading Edge Alliance North American Conference, International Tax Group
  • Praxity North American Tax and Fiscal Conferences
  • Philadelphia Tax Conference (Conference Chair, 2008-2010 and 2012)
  • Tax Executives Institute
  • Strafford Publications - International Tax Webinars
  • "The Quest for U.S. Tax Reform: Fact or Fiction," Accounting Today, August 20, 2014
  • "Global Tax Reform: Place Your BEPS," CPA Now, www.picpa.org, September 02, 2015
  • "Reclassification of Related Party Corporate Debt: Treasury Proposes New Section 385 Regulations," Bloomberg BNA, Daily Tax Report July 01, 2016
Subject Matter Expertise

Multinational Transaction Planning
Cross-Border Capitalization
Repatriation Strategies
Mergers and Acquisitions
Inter-Company Transfer Pricing
Acquisition Due Diligence Review
Foreign Tax Credit Management
Treaty Interpretation

Education

Bachelor of Arts, 1977
University of Pennsylvania

Juris Doctor, 1980; Master of Law in Taxation, 1984
Villanova University School of Law

Related News

Proposed Section 965 Regulations Related to Transition Tax


Tax Flash - International Taxation

Proposed Section 965 Regulations Related to Transition Tax

On Wednesday, August 1, 2018, the Internal Revenue Service issued proposed regulations under the repatriation tax provisions of Section 965 enacted as part of the ....

IRS Issues Notice to Explain New Toll Tax


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Global Intangible Low Taxed Income: A Step Away from Territorial

The new tax reform law has been widely touted by the media as transforming the U.S. into a territorial system of taxation as used by ....

Long Island Business News featured International Tax Co-Leader Doug Nakajima in an article about the repatriation of foreign earnings by U.S. companies.


As Seen In

Long Island Business News featured International Tax Co-Leader Doug Nakajima in an article about the repatriation of foreign earnings by U.S. companies.

For many years, many U.S. multinational companies hoarded cash abroad. As long as they didn't bring money they earned abroad back to the United States, ....

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Press Release

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Transition or Imposition - Shareholders Beware of the 2017 Transition Tax on Foreign Earnings


Tax Flash - International Taxation

Transition or Imposition - Shareholders Beware of the 2017 Transition Tax on Foreign Earnings

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IRS Issues Revised Form W-8BEN-E and Instructions


Tax Return Compliance

IRS Issues Revised Form W-8BEN-E and Instructions

On April 16, 2016, the IRS released an updated version of Form W-8BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and ....

Treasury Issues Final Section 385 Regulations on Reclassification of Related Party Corporate Debt


Tax Flash

Treasury Issues Final Section 385 Regulations on Reclassification of Related Party Corporate Debt

On October 14, 2016, the U.S. Treasury Department issued final regulations addressing whether an interest in a corporation is to be treated as stock or ....

Marcum Announces New International Tax Leaders


Press Release

Marcum Announces New International Tax Leaders

Marcum LLP, a top national accounting and advisory services firm, named Mark Chaves, CPA, and Douglas Nakajima, J.D., LL.M., as co-leaders of the Firm's International ....

International Tax Co-Leader Doug Nakajima authored an article about new Section 385 regulations governing the classification of corporate debt, for Bloomberg BNA’s Daily Tax Report.


As Seen In

International Tax Co-Leader Doug Nakajima authored an article about new Section 385 regulations governing the classification of corporate debt, for Bloomberg BNA’s Daily Tax Report.

Douglas Nakajima of Marcum LLP looks at the operation of the IRS proposed rules (REG-108060-15) that would allow related-party corporate debt to be reclassified as ....

 
 
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