Managing Director, International Tax, Washington National Tax, 乐鱼(Leyu)体育官网 US
Rose Jenkins
Managing Director, International Tax, Washington National Tax
Rose is a Managing Director in the International Tax Group within 乐鱼(Leyu)体育官网鈥檚 Washington National Tax office.聽
Rose advises clients on U.S. international tax matters, with an emphasis on outbound tax issues. In particular, she has experience advising on issues relating to the subpart F and passive foreign investment company (PFIC) rules.
Prior to joining 乐鱼(Leyu)体育官网 in February 2020, Rose was in the Office of Associate Chief Counsel (International) at the Internal Revenue Service (IRS) for six years, finally as a Special Counsel聽 Throughout her time at the IRS, she worked extensively on regulations and other administrative guidance and assisted in developing IRS positions during exams, appeals, and litigation.聽 At the IRS, Rose worked on guidance related to section 956, inversions, and section 385.聽 After enactment of the Tax Cuts and Jobs Act, Rose focused on guidance implementing U.S. tax reform, including regulations implementing the transition tax, GILTI, and the PFIC regime and guidance related to the repeal of section 958(b)(4).聽