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Jonathan Prokup's practice encompasses a broad array of tax matters, from structuring complex financial transactions to representing clients in all facets of tax controversy, including audits, appeals and litigation. He possesses particular expertise with the tax consequences of financial instruments, including exotic collaring mechanisms and illiquid swap contracts, with an emphasis on the use of such instruments in cross-border transactions.
Mr. Prokup advises both domestic- and foreign-based multinational corporations and has achieved numerous favorable outcomes for his clients in multi-million dollar disputes with the IRS. | 