Ben Willis is a director with Baker Tilly’s Washington tax council practice. He is a tax practitioner, author and adjunct professor with deep technical expertise and innovative planning skills, drawing from more than 15 years of government service and private sector experience.
- Developed strategies to maximize the recovery of all federal and state tax refunds
- Prepared and filed Forms 1120-Xs and 843s and analysis to support close to $100 million in tax refund claims
- Designed tax software by integrating law with predictive analytics and machine learning
- Analyzed new laws and determined their impact on taxpayers
- Collaborated with law and accounting firms and government agencies to build tax tools to improve the efficiency, effectiveness and confidence of their tax staff
- Representative speaker and guest panelist in prominent forums including the Irish Tax Institute
- Maintained private sector and government contacts to stay abreast of relevant issues
- Collaborated on the development and negotiation of key tax policy with the staff of the U.S. House of Representatives’ Ways & Means Committee, the Joint Committee on Taxation (JCT), Treasury and the IRS
- Developed legislation, writing memoranda and speaking to outside groups on behalf of the Senate Finance Committee
- Designed and presented details of a comprehensive U.S. international tax reform proposal that included new rules for corporate and pass-through entities
- Provided key improvements to proposed legislation on territoriality, integration, inversion, outbound transfer rules, and the deferral of foreign earnings and other income of controlled foreign corporations
- Managed interactions between JCT and legislative counsel to help draft and score legislative proposals
- Advised clients on issues surrounding corporate tax rates, debt and equity, substance over form doctrines, loss and attribute utilization, ownership/equity structuring, PLRs, basis calculations, basis and E&P allocation methods, mergers and acquisitions, and internal restructurings
- Provided Fortune 500 companies with comprehensive tax consulting services
- Coordinated a team of firm partners and senior staff in addressing choice of entity following the 2017 Tax Cuts and Jobs Act (TCJA), implemented newly created firm policies designed to enhance the corporate tax practice, and worked with other practice leaders to address the complex intersections of various tax areas, including corporate tax, pass-through tax, international tax and the taxation of financial products
- Provided analysis and planning guidance on international tax issues regarding subpart F inclusions, the new GILTI minimum tax, the BEAT minimum tax, and maximizing section 250 deductions for GILTI and FDII
- Managed drafting, reviewing and issuing guidance on corporate tax
- Reviewed and signed off on corporate tax field memos, informal chief counsel advice, litigation matters, letter rulings, and published guidance on law involving formations, reorganizations, spin-offs, distributions, redemptions, liquidations, contributions, bankruptcies and consolidated returns
- Massachusetts Bar Association
- Work, Community, Independence (WCI) Human Rights Committee, member and appointed attorney
- Whitmarsh House, mentor and volunteer
- Authored roughly 100 technical articles on cutting-edge international and federal tax planning issues
- “Embracing the Certainty of Change,” author, Tax Executive, November 2021
- “Building Back Biden’s American Start-Up,” co-author, 173 Tax Notes Federal 1247, November 2021
- “The Potential for Tax Enforcement Through Sub regulatory Guidance,” co-author, 173 Tax Notes Federal 959, November 2021
- “Treasury’s Growing Tax Enforcement Power,” author, 173 Tax Notes Federal 345, October 2021
- “Releasing the Hook from Zero-Basis Stock,” author, 172 Tax Notes Federal 1979, September 2021
- “Foreign Trust Penalties: Substance Over Forms,” author, 103 Tax Notes Int'l 1136, August 2021
- “Realizing Deemed Income from ‘Holey’ New Taxes,” author, 172 Tax Notes Federal 1293, August 2021
- “Foreign Trust Penalties: Substance Over Forms,” author, 103 Tax Notes Int'l 1136, August 2021
- “Realizing Deemed Income from ‘Holey’ New Taxes,” author, 172 Tax Notes Federal 1293, August 2021
- “When Are New Taxes Unconstitutional for Revenue-Raising?”, author, 172 Tax Notes Federal 779, August 2021
- “S Corporations Aren’t Worthless for Ordinary Stock Deductions,” author, 172 Tax Notes Federal 239, July 2021
- Biden’s Global Tax Competition,” author, 102 Tax Notes Int'l 1754, June 2021
- “The End of Zero-Basis Springing Debt for Partnerships,” author, 171 Tax Notes Federal 1771, June 2021
- “Taxpayer Deference Can Help Close the Tax Gap,” author, 171 Tax Notes Federal 1229, May 2021
- “Executive Overreach Has Doomed the Territorial DRD Regulations,” author, 171 Tax Notes Federal 759, May 2021
- “Springing the End of Zero-Basis Debt for S Corporations,” author, 171 Tax Notes Federal 431, April 2021
- “The Wealth Tax Trump Would Be Happy to Pay,” co-author, 171 Tax Notes Federal 73, April 2021
- “Springing the End of Zero-Basis Debt,” co-author, 170 Tax Notes Federal 1871, March 2021
- “Biden and Harris’s High Hopes for International Tax Fairness,” co-author, 101 Tax Notes Int'l 1386, March 2021
- “Will 'America First' Leave America Alone?”, author, 101 Tax Notes Int'l 1099, March 2021
- “Jeffrey Epstein’s Special Trusts,” co-author, 170 Tax Notes Federal 957, February 2021
- “The TCJA’s Unilateral Provocation of DSTs,” co-author, 170 Tax Notes Federal 591, January 2021
- “Congress Expands Gitlitz to Triple Tax Benefits for PPP,” author, 170 Tax Notes Federal 293, January 2021
- “Planning Possibilities for PPP Deductions,” co-author, 170 Tax Notes Federal 79, January 2021
