Jeffrey Vinnik is an attorney with the IRS’ Office of Chief Counsel (International) in Washington, DC, where he has over time focused on inbound financing (earnings stripping); thin capitalization issues; controlled foreign corporation (CFC) and passive foreign investment company (PFIC) issues; and tax treaty issues. He has served at the Treasury’s Office of International Tax Counsel (ITC); in the IRS’ former Office of Senior Counsel; and with the Joint International Tax Shelter Information Centre (JITSIC), where he helped identify and develop challenges to a variety of cross-border abusive tax structures. Prior to joining the IRS, he was associated with law firms in Boston, Miami, and New York. He is a graduate of Yale College and the Harvard Law School.