Stafford Smiley is a Senior Counsel in Caplin & Drysdale's Washington, D.C. office and a Professor in the Graduate Tax LLM Program at Georgetown University Law Center.
Mr. Smiley began his legal career as a law clerk to Judge Arnold Raum of the United States Tax Court. He joined Caplin & Drysdale in September 1978 and became a member of the firm in January 1983.
Mr. Smiley's practice focuses on the taxation of partnerships, S corporations, and other pass-thru entities. He also works generally on business taxation issues and issues relating to the ownership and transfer of assets for tax purposes. He has extensive experience as tax counsel in international financing, leveraged lease, and other transactional settings.
Mr. Smiley represents a number of large family-held businesses, for whom he provides not only business tax advice but also general business, trust, estate, and gift advice.
Mr. Smiley also represents a number of international finance organizations, for whom he does international tax planning work, primarily in the areas of international structured finance and transfer pricing matters (including especially advanced pricing agreements).
Mr. Smiley has taught in the Graduate Tax Program at Georgetown University Law Center as an Adjunct Professor since 1996. He became a Visiting Professor in 2008 and a Professor in 2010. In the Spring of 2012 he will be teaching a course on Income Tax Accounting. Prior to teaching at Georgetown, he was an Adjunct Professor at the George Washington University Law Center. Mr. Smiley has lectured at the New York University Annual Institute on Federal Taxation, the University of Virginia Law School, and other tax-oriented educational institutions. He holds a Professorship at the University of Lodz (Poland) and teaches and lectures extensively in tax programs at universities abroad. Also, he has lectured on the Basics of U.S. Tax Audit and Tax Litigation at Caspian "Social" University in Almaty, Kazakhstan, and instructed a two-week master class on U.S. International Tax in the Public Finance Masters program at Moscow State Institute of International Relations (MGIMO).
Mr. Smiley served for many years as the International Developments Editor for the Journal on Partnership Taxation, and now serves as International Developments Editor for Corporate Taxation. In 2006, Mr. Smiley became the Examiner in U.S. Tax Law for the Chartered Institute of Accounts in the United Kingdom.
Awards & Honors
- AV rated by Martindale-Hubbell
- Ranked as a leading lawyer in Tax Law and Trusts and Estates in the 2013 edition of Best Lawyers
- U.K. Excess Profits Tax Under U.S. Foreign Tax Credit, Corporate Taxation (January/February 2013)
- Foreign Tax Credit Generators, Corporate Taxation (May/June 2012)
- Case Updates-Dell Products (Norway) General Electric Capital (Canada) SNF (Australia), Corporate Taxation (March/April 2012)
- Commissionaire and Contract Manufacturing Arrangements--New Developments on Permanent Establishment Issue, Corporate Taxation (January/February 2012)
- Taxation of Passive Foreign Investment Companies: Current Rules, Problems and Possible Solutions, Corporate Taxation (November/December 2011)
- Qualified Intermediaries, The EU Savings Directive, Trace--What Does FATCA Really Add, Corporate Taxation (September/October, 2011)
- India's Proposed Direct Taxes Code--Highlights For Corporate Taxpayers, Corporate Taxation (July/August 2011)
- ITPF--Georgetown University Law Center Conference on Reform of International Tax, Corporate Taxation (May/June, 2011)
- Putting an End to Foreign Tax Credit 'Splitting' Transactions, Corporate Taxation (March/April, 2011)
- President Obama's Efforts at International Tax Reform, Corporate Taxation (January/February, 2011)
- 2010 Treaty Developments, Corporate Taxation (November/December, 2010)
- A Shift Toward Consumption Taxes: The Tax Policy Prescription For The Fiscal Ills of The Global Financial Crisis, Corporate Taxation (July/August, 2010)
- Loan Guarantees and Transfer Pricing, Corporate Taxation (May/June, 2010)
- National Westminster Bank: Will the IRS Ever Give Up, Corporate Taxation (March/April, 2010)
- The Curious Case of The Partial Loophole Closer, Corporate Taxation (January/February, 2010)