Senior Manager, Financial Services Senior Analyst
Areas of focus: Financial Services
In May 2020, Jamison was selected as a senior analyst in RSM’s cutting edge Industry Eminence Program, which positions its senior analysts to understand, forecast and communicate economic, business and technology trends shaping the industries RSM serves. These senior analysts advise clients on conditions influencing middle market leaders. Jamison’s focus is on the financial services industry.
Summary of experience
Jamison has more than ten years of experience providing consulting and international tax advisory services. He serves as an RSM subject matter expert on foreign tax credits and has significant experience with global effective tax rate management, supply chain restructuring and cross-border mergers and acquisitions (M&A). Jamison advises clients in regulatory matters such as competent authority requests, penalty abatement procedures and IRS examinations. He also serves as the firm’s blockchain and digital asset tax lead. In this capacity, he assists blockchain clients in determining the unique regulatory and tax consequences of their global operations.
Professional Affiliations and Credentials
- Licensed to practice law in North Carolina and the District of Colombia
- Member of the Leadership Committee for the Digital Chamber’s Tax Task Force
- LL.M. in Taxation, with Distinction, International Tax Certificate, Georgetown University Law Center
- J.D., University of North Carolina at Chapel Hill
- B.S.B.A., with Distinction, Kenan-Flagler Business School, University of North Carolina at Chapel Hill
Recent Publications and Presentations
- “Crypto and E-money Tax Reporting Issues” presented to OECD Working Party 10, April 2020.
- “View From Exchanges” panelist at IRS Virtual Currency Summit, March 2020, Washington, D.C.
- “International Tax Planning Update” presented to TEI Tampa, February 2020.
- International Tax Considerations for the Blockchain Industry, The Tax Adviser (April 2019).
- GILTI: A New Age of Global Tax Planning, The Tax Adviser (April 2019).
- “Future of Crypto Regulations” panelist at Blockchain Innovators Summit 2018, Ibiza, Spain.
- “Decrypting Crypto: Policy, Security and Regulatory Challenges” panelist at YPO-NSI Blockchain Technologies Summit 2018.
- Economic Forecast & Trends 2018: Tax Reform - International Planning Considerations, Los Angeles Business Journal.
- Do You Know the Balance in Your ODL or OFL?, 91 Taxes 53.
A look at the changing regulatory landscape for the financial services industry under the Biden administration.
Final section 864(c)(8) regulations clarify rules for foreign partners with ECI from transfers of partnership interests.
RSM is pleased to offer a webcast on the AICPA’s practice aid on accounting for and auditing of digital assets.
The CARES Act enacted a temporary suspension of the TCJA’s 80% limitation on the use of NOLs, this will impact FTC and ODL calculations.
Final FTC regulations provide clarity while Treasury takes a stance against permitting a credit for digital taxes in new proposed rules.
Updated IRS materials suggest a renewed and heightened focus on the reporting of virtual currency transactions by taxpayers.
Taxpayers may not be aware that their business activities with Canada may give rise to a reporting requirement, or even a tax liability.
A foreign tax credit transaction that was previously referenced in Notice 2004-20 has been removed by the IRS.
The IRS is willing to consider relief from double taxation resulting from the application of section 965 in limited circumstances.
The IRS finalized rules for withholding and reporting U.S. source payments to foreign individuals and financial institutions.