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David M. Hryck is Tax Partner in the New York office of DLA Piper a global law firm with over 3,400 lawyers and a presence in more than 25 countries. His practice is focused on advising privately and publicly held clients on the tax aspects of structuring business transactions, including, advising on new business opportunities, joint ventures, and corporate global mergers and acquisitions. He has distinct experience in structuring the tax aspects of international cross- border mergers and acquisitions and other off-shore |
business investments and assists multinational corporations with managing their global effective tax rates. In addition to multinational corporations, David represents many high profile individuals and international families and manages their global tax and business planning.
KJ- David, what factors contributed to your entering the tax and legal profession? DH- I especially enjoy the opportunity to be involved in the structuring business transactions and the ability to really bring value to a client. Managing effective tax rates for both corporations and families involves meeting people from all over the world and that's really exciting and interesting.
KJ- I understand that you speak four different languages (French, Italian, Spanish and English). What motivated you to learn these other languages?
DH- My principal motivation was to broaden my cultural horizons and then it became like a hobby as I realized languages came kind of natural to me. I also like learning about and meeting people as well as understanding their culture and what motivates them. I was actually a late bloomer with languages and learned French, Italian and Spanish after the age of 30, but it was one of the best things I ever did for myself. Although I didn't study languages for business reasons, it has actually been very helpful to my practice. I have many clients who are foreign based multinationals and some clients who are very foreign wealthy individuals. The opportunity to relate to them by speaking their language helps quite a bit. Certainly with multinationals, you are working with their foreign operations and employees all over the world . If you can speak the language, you can quickly relate to them in a different way.
KJ- People from each country experience things from their own perspective. What have you learned while you are working outside of the United States?
DH- Obviously, the culture is very different in other countries; one simply cannot successfully do business with people in Europe the same way you do business in the United States. There is a really big trust factor when interacting with other cultures and one needs to take time with the people and get to know them so that they comfortable with who you are and what you represent. Without that, the relationship will not move to the next level. A key aspect of this is getting on an airplane and going to see the client even if they are in another country. It is as important to know your clients well as it is to do excellent legal work.
KJ- What trends do you see developing outside of the United States?
DH- In Europe, the trend is towards lowering tax rates. This has seemed to follow the natural evolution of business as the business of many US based multinationals appears to be increasing outside of the US in Europe and Asia. When you look at the profile of a multinational corporation today, you shouldn't be surprised if you see that the non US portion of their international business may have increased or is projected to increase significantly in a disproportionate way relative to the US portion. For example, if they are a manufacturer, they are probably selling more outside the US than they ever were and maybe even more than they are selling in the US right now. There are certainly more opportunities for multinationals today to reconfigure their operations in a tax efficient way given that in many cases the business naturally seems to be moving off-shore.
KJ- What are the tax rates in European countries these days?
DH- The latest trend in Europe has been to lower tax rates so that the tax rates are generally in the mid 20’s or so. Germany has always had one of the highest tax rates and but even Germany has lowered its tax rate.
KJ- What do you see in Asia? DH- Obviously, China and India are two really hot markets for multinational corporations. China has made changes in its tax rules recently and has leveled the playing field for foreign investors and local Chinese investors. Historically, non-Chinese residents investing in China had tax advantages over residents, which is no longer the case. However, there are still tax planning opportunities to help non-Chinese residents minimize the tax burden of investing in China. For example, a recently enacted tax treaty with Hong Kong leaves open various opportunities to move profits out of China in a tax efficient way. In India, we have seen the creation over the last few years of more and more special tax zones where the tax rate is lower or even zero in some case. KJ- What advice would you give newcomers to the tax profession?
DH- The tax profession offers many opportunities to newcomers to be creative and helpful to clients, and meet and spend time with people from all over the world. However, a newcomer should really be focused in the early years on developing a strong technical base of information and skills. It generally takes longer in the tax profession to do this than other areas of law because tax is so technical. If you then layer international tax on top of that, you have to consider the special US international tax rules as well as the basic fundamental knowledge of the tax laws in other countries. So be patient, but not too patient because it doesn't stop there. A tax practitioner also has to get to know the clients, understand what they need and be able to explain some very complicated rules in a simple way. And that's really all part of developing the client's trust and friendship. KJ- David, thank you for the time you gave us to answer our questions. Your perspective is valuable to the Tax Intelligence Report readers around the world. We genuinely appreciate the time you gave to share your experience.
Kathleen Jennings (KJ)
Editor, The Tax Intelligence Report
Kathleen@etsearch.com
If you would like an introduction to DLA Piper Rudnick or if you would like to send a private email to David, please contact Kathleen Jennings at Kathleen@etsearch.com.
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