Irving Salem retired from Partnership on December 31, 2004.
From 1960 to 1965, Mr. Salem worked at the IRS and the Treasury Department. In 1960, he joined the Office of Chief Counsel, Internal Revenue Service (the Legislation and Regulations Division). He moved to the Treasury Department, in the office of Tax Legislative Counsel from 1962 to 1963, and then became the Technical Assistant to the Chief Counsel of the IRS from 1964 through 1965. Among other assignments, he was in charge of the IRS/Treasury task force that led to a major revision of the consolidated return regulations.
Mr. Salem has had significant Washington D.C. experience (i.e., rulings, regulations and lobbying), as well as extensive experience in planning corporate acquisitions and restructurings, handling audit controversies and in litigating tax issues.
Mr. Salem is a frequent author and lecturer on a variety of federal income tax issues, including INDOPCO, insurance, acquisition agreements, consolidated return and NOL issues and the tax impact of judicial deference to agency determinations. He has published three articles in 2002: "Rite Aid: Potentially Historic," "Insuring the Risks of Brother/Sister Corporations: Think Captive" and "Proposed Regulations Provides Creative and Helpful Guidance for Insurance Acquisitions – But Imposes Major New Capitalization Requirements."
Mr. Salem has been a member of the Executive Committee of the New York State Bar Association where he co-chaired the Consolidated Return and the Insurance Committees. He has also been an active member of the Section of Taxation of the American Bar Association and chaired an ad hoc committee (under the Court Procedure and Practice and the Administrative Practice committees) looking into the proper scope of judicial deference to IRS regulations, rulings and notices.