About

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Alexis Fallon is a tax attorney who specializes in U.S. possessions (Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, and Commonwealth of the Northern Mariana Islands) and international tax issues.

Alexis Fallon JD, LLM Experience

July 2003-Present

Fallon Law Offices, Saipan MP 96950

Position

Represent clients with CNMI, IRS and international tax issues; Pending class action against the CNMI government for failure to pay rebate claims from 2002 to present and associate interest in the amount of $39.5 million dollars; Settled $400,000 IRS claim for failure to file w-2’s electronically for large scale employers this led to corrective IRS publication; successfully defenOffice of the Attorney General, Saipan, MP;
Position
Tax Legal Counsel; Special Assistant Attorney General; Disclosure Officer Division of Revenue and Taxation

Advised and coordinated internal policies for Exchange of Information program between the Internal Revenue Service and the CNMI. Prosecuted tax collection matters generating $600,000 dollars within the first three months of collection activity for bounced checks for tax payments.
ded a $258,000 trust fund recovery penalty for failure to pay FICA where the person of interest was deemed a “consultant” and not a responsible person; discovered ‘cover over’ funds due from the Federal government to the CNMI government approximate amount of the claim $60 million dollars; Settled individual cover over claims with the IRS for $8 million dollars; Lead counsel in the negotiations for CNMI in the Tax Coordination Agreement between the Commonwealth of the Northern Mariana Islands and the United States. Consulted with Office of Chief Counsel, Branch 7, IRS regarding procedures for electronic reporting of FICA payments of CNMI corporations.

Nov. 2001-June 2003

Office of the Attorney General, Saipan, MP;
Position
Tax Legal Counsel; Special Assistant Attorney General; Disclosure Officer Division of Revenue and Taxation

Advised and coordinated internal policies for Exchange of Information program between the Internal Revenue Service and the CNMI. Prosecuted tax collection matters generating $600,000 dollars within the first three months of collection activity for bounced checks for tax payments.

Oct. 1999-June 2001

PricewaterhouseCoopers LLP- Boston, Massachusetts

Position
Senior Consultant-International Tax Group

Research and writing on international mergers and acquisitions, inbound and outbound transactions, and treaty analysis. Advised on international tax issues for a U.S. client involved in an Initial Public Offering. Assigned to PricewaterhouseCoopers Entrepreneurial Center in Cambridge, Massachusetts to advise start-up corporations on international tax issues. Implemented corporate structures for foreign corporations and U.S. corporations in tax advantaged jurisdictions. Research the impact of migrations of intellectual property to reduce the overall effective tax rate. Reviewed inter-company agreements for transfer pricing compliance. Assisted in amending an Advance Pricing Agreement with the IRS.

July 1998-Sept.1999

Arthur Andersen LLP- Boston, Massachusetts

Position
Senior Consultant-International Tax Group

Advised on international tax issues for multinational corporations. Analyzed financial instruments structures and foreign currency impacts. Managed Form 5471 compliance project for large publicly traded company. Advised on expatriate tax issues. Assisted in high net worth Canadian individual estate planning- specifically analyzing the impact of a Canadian Estate Freeze for U.S. resident. Advised on FIRPTA issues. Advised on U.S. stock option plans impact for non-U.S. employees.

PUBLISHED WORKS

“Hide and Seek: The “Retroactive” Informational Reporting Requirements in the U.S. Possessions, Journal Of Tax Practice and Procedure, Published by CCH, June-July 2007
“Attorney Recommends changes to Proposed Regs on
Possession Source Rules, Tax Notes Today, August 5, 2005

“Taxman Cometh to the U.S. Possessions”, Tax Notes International, February 14, 2005

ADMITTED TO PRACTICE

Massachusetts, CNMI

EDUCATION

Boston University School of Law, Boston, MA
Master of Taxation (LLM)

Suffolk University Law School, Boston, MA
Juris Doctorate
Honors: Dean’s List

University of New Mexico School of Law. Alb., NM
Visiting Student
Honors: Dean’s List; International Moot Court Finalist.

McGill University. Montreal, Quebec, Canada
Bachelor of Arts,
Honors: Honors Economics Program
Major in Economics, Minor in Latin American Studies

LANGUAGES

Spanish-fluent; Japanese-Intermediate; Chinese-beginner.