Marcellin N. Mbwa-Mboma

Prior to joining the firm, Marcellin served as an international tax partner at one of the leading global law firms and one of the largest professional services firms in the world.

Marcellin's practice regularly responds to global events impacting corporations and their financial interests. For example, since 2020, Marcellin has advised corporations through the coronavirus pandemic in deconsolidation structures to cost-effectively utilize losses in US operations of multinational corporations. In addition, during periods of financial volatility, Marcellin has focused his attention on offshore debt-buy back structures for private equity funds and their US portfolio companies to eliminate cancellation of indebtedness income and secure withholding tax exemption on interest payments.

Drawing on nearly three decades of legal practice, Marcellin is also adept at advising clients on important tax-related legislation and regulations that impact US and foreign-headquartered multinational groups and private equity funds. Specifically, he has modeled out the impacts and the regulations of the US Tax Cuts and Jobs Act of 2017 and advised multinational corporations on global supply chain transformations to take advantage of a reduced US corporate tax rate under the FDII regime, yielding over 50 billion of tax benefits annually and, on global minimum tax planning and compliance.

• American Bar Association, Member
• New York State Bar Association, Member
• Education Solutions, Inc., Chairman of the non-profit organization.
  • Education Solutions, Inc. provides free academic instruction and leadership training to promising Congolese children and youth who have demonstrated academic and leadership potential. Education Solutions, Inc. supports program participants from elementary school through to College and University. Our programs include scholarships for academic instruction, leadership training, and education system solutions and capacity-building.

Marcellin has lectured extensively on US international tax issues at events sponsored by the International Fiscal Association, New York branch, Bloomberg BNA and Council for International Tax Education (CITE), the European-American Tax Institute, the Tax Executive Institute, Baker & McKenzie, Ernst & Young, and the University of Rennes (France), and has received numerous star speaker awards.

• Speaker, Panel: Inbound topics focusing on BEAT regulations and 163(j); International Fiscal Association USA Branch, New York Region, Fall Conference, 13 December 2019

• “IRS Clarifies 'Foreign Derived' Service Income for FDII Regime,” Bloomberg Tax: Tax Management International Journal, March 2025
• “Identifying base erosion payments and waiving deductions under the final and new proposed BEAT regulations,” Tax Management International Journal, March 2020
• “L’expatriation des sociétés américaines, un outil de gestion fiscale du patrimoine,” Revue de Droit Fiscal, 24 May 2012 
• “Gain Recognition Agreements and Reasonable Cause Exception,” Tax Notes International, 11 January 2010
• “New Regs Clarify Ruling Requirements for Tax-Free Spin-Offs,” Tax Notes International, 17 November 2003, pp.633–637 
• “The Push Toward Pan-European Tax Consolidation,” Tax Notes International, 5 May 2003, pp.457–465, Doc 2003-1113; European Tax Newsletter, Baker & McKenzie, May 2003 
• “Planning Opportunities, Limits of the New Tax Definition of Merger,” Tax Notes International, 23 December 2002, pp.1211–1220
• “France-Switzerland Treaty Overrides CFC regime, French Tax Court Rules,” Tax Notes International, 8 July 2002, pp.143–150
• “France, OECD take different views of unstaffed servers as permanent establishments” Tax Notes International, 3 June 2002, pp.1107–1111; Tax Planning International E-commerce, June 2002, pp.6–8
• “Intégration Fiscale: La Scission de la Société Mère Facilitée” Les Echos, October 1996

• Quoted, “K&L Gates Boosts Houston Shop with Ernst & Young Tax Ace,” Law360 Pulse, October 2024