Allen Sullivan Jr.

Allen Sullivan is a partner in Bradley’s Corporate & Securities and Tax practice groups who works with U.S. and foreign clients involved in various industries providing corporate, M&A, private equity, tax, and international trade (including export controls and CFIUS) and related compliance strategies.

Allen’s corporate, M&A, and private equity practice involves many aspects of corporate law, including mergers, acquisitions and dispositions, foreign direct investment, joint ventures, corporate and fund formations, private placements, and tax-free reorganizations.

Recognized in The Best Lawyers in America® for Tax Law since 2022, Allen’s tax background includes both tax planning and tax controversy matters. His tax planning experience includes individual, “C” corporation, “S” corporation, partnerships/LLCs, executive compensation, and international tax matters, to name a few. His tax controversy work includes complex audits, IRS Appeals negotiations, large collections matters, penalty abatements (domestic and international), Tax Court litigation, and various types of voluntary disclosures.

In his international trade and compliance practice, Allen advises clients on export control matters involving the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR), transactions involving the Committee on Foreign Investment in the U.S. (CFIUS), Foreign Corrupt Practices Act (FCPA) matters, and sanctions matters involving the Office of Foreign Assets Control (OFAC). To help his clients comply with these various regimes, Allen tailors their in-house policies and programs to their particular products, technology, services, customers, workforce, and relevant international or domestic footprint. For businesses with export control concerns, this often includes helping classify their products and technology under the EAR and the ITAR. On the anti-corruption and sanctions front, this process often includes third-party due diligence related to the ever-changing OFAC sanctions landscape.

Allen also has represented foreign buyers and U.S. sellers in foreign direct investment transactions involving CFIUS considerations, some resulting in notices and declarations that the committee ultimately approved. His CFIUS experience also includes negotiating conditions for CFIUS approval, drafting national security agreements designed to protect U.S. national security following CFIUS approval, and working with the committee to restructure companies that are subject to ongoing CFIUS monitoring following committee approval.

During his legal career, Allen has represented over 100 U.S. citizens and residents, dual citizens and their families, and related entities in properly reporting their offshore holdings for U.S. tax purposes, and in reconciling previous compliance missteps, failures, and deficiencies. Through this work, he has represented taxpayers in every iteration of the IRS’s Offshore Voluntary Disclosure Initiatives, such as the OVDP (including “opt outs”), streamlined procedures, and others.