Financial Services

Marks Paneth is dedicated to helping financial institutions and other members of the financial services sector succeed within the distinct dynamics of their industry. With today’s global economies and changing tax laws, financial services firms need the right tax advisor to help them face both domestic and international tax issues.

The professionals in Marks Paneth’s Financial Services practice advise banks, broker-dealers, asset managers, funds and institutions on strategic tax planning and compliance for both domestic and international business activities. Our advisors are highly skilled in the areas of withholding examinations, qualified intermediary audits, tax form updates, and deductions, allocations and apportionments under the IRC and the Authorized OECD Approach, as well as the nuances of section 475 for mark-to-market items.


  • Section 475, including valuation
  • Broker/dealer issues, including global dealing, permanent establishment attributions, customer documentation
  • Sales and revenue growth planning
  • Section 199A
  • Interest allocation and apportionment
  • Section 263 and 263A
  • Lending into the US as a trade or business
  • Custodial and payment services issues
  • Withholding under Chapter 3, including section 871(m), and Chapter 4 FATCA
  • Qualified Intermediary issues
  • Introductory, executing, and clearing broker issues, including delivery vs payment considerations
  • Financial institution issues, including tax accounting and regulatory capital requirement issues
  • Tax review of exotic products
  • BASEL 3
  • Dodd-Frank
  • Compliance and information reporting
  • Controversy, including IRS examinations of asset managers, managed funds, retail and investment banking, prime brokerage and custodial services
  • Financial products taxation


Mark R. Baran
Julio M. Jimenez