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Marcum LLP

Douglas Nakajima

J.D., LL.M
Douglas  Nakajima, International Tax Co-Leader, Tax & Business
International Tax Co-Leader
Tax & Business

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Philadelphia, PA 19103

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Douglas Nakajima is co-leader of Marcum's International Tax Services Practice and a director in the Firm's Tax & Business Services Division. He came to Marcum in 2015 via the Firm's merger with Smart Devine, a leading full-service accounting firm in Philadelphia.

Mr. Nakajima has over 30 years of experience in federal and international tax and strategic business planning, advising a diverse client base of U.S. and multinational manufacturing, service and technology and financial services businesses. He has advised public and private clients on the tax treatment of domestic and cross-border transactions, inbound and outbound business expansion strategies, domestic and cross-border acquisitions, dispositions and reorganizations, intercompany transfer pricing, treaty interpretation, and repatriation planning. He has worked extensively with tax advisors in foreign countries to develop global structures that minimized U.S. and foreign tax exposures, and in this role, has forged effective working relationships with key professionals throughout North America, Europe, Asia and the Pacific Rim.

Mr. Nakajima's previous experience includes tax leadership positions with international, national and regional accounting firms. He also served as tax counsel to a Fortune 100 corporation, where he was responsible for the restructuring of the company following its acquisition of a foreign-owned U.S. competitor. Mr. Nakajima is an attorney admitted to practice in Pennsylvania.

Professional & Civic Affiliations
  • White Horse Village, Inc., Board of Directors
  • Philadelphia Tax Conference, Inc., Board of Directors
  • IGAF Worldwide, North America, Board of Directors (Former)
Articles, Seminars & Presentations
  • Chicago Tax Club
  • IGAF Worldwide North American and European Group Tax Conferences
  • Leading Edge Alliance North American Conference, International Tax Group
  • Praxity North American Tax and Fiscal Conferences
  • Philadelphia Tax Conference (Conference Chair, 2008-2010 and 2012)
  • Tax Executives Institute
  • Strafford Publications - International Tax Webinars
  • "The Quest for U.S. Tax Reform: Fact or Fiction," Accounting Today, August 20, 2014
  • "Global Tax Reform: Place Your BEPS," CPA Now, www.picpa.org, September 02, 2015
  • "Reclassification of Related Party Corporate Debt: Treasury Proposes New Section 385 Regulations," Bloomberg BNA, Daily Tax Report July 01, 2016
Subject Matter Expertise

Multinational Transaction Planning
Cross-Border Capitalization
Repatriation Strategies
Mergers and Acquisitions
Inter-Company Transfer Pricing
Acquisition Due Diligence Review
Foreign Tax Credit Management
Treaty Interpretation


Bachelor of Arts, 1977
University of Pennsylvania

Juris Doctor, 1980; Master of Law in Taxation, 1984
Villanova University School of Law

Related Insights & News

Long Island Business News featured International Tax Co-Leader Doug Nakajima in an article about the repatriation of foreign earnings by U.S. companies.


For many years, many U.S. multinational companies hoarded cash abroad. As long as they didn't bring money they earned abroad back to the United States, ....

Marcum LLP Designated by IRS as Certified Acceptance Agent


Marcum LLP is now designated a Certified Acceptance Agent (CAA) by the Internal Revenue Service (IRS). The CAA designation establishes Marcum as an agent of ....

Transition or Imposition - Shareholders Beware of the 2017 Transition Tax on Foreign Earnings


The transition tax is a mandatory one-time tax to be imposed on U.S. shareholders that own 10 percent or more of the shares of a ....

IRS Issues Revised Form W-8BEN-E and Instructions


On April 16, 2016, the IRS released an updated version of Form W-8BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and ....

Treasury Issues Final Section 385 Regulations on Reclassification of Related Party Corporate Debt


On October 14, 2016, the U.S. Treasury Department issued final regulations addressing whether an interest in a corporation is to be treated as stock or ....

Marcum Announces New International Tax Leaders


Marcum LLP, a top national accounting and advisory services firm, named Mark Chaves, CPA, and Douglas Nakajima, J.D., LL.M., as co-leaders of the Firm's International ....

International Tax Co-Leader Doug Nakajima authored an article about new Section 385 regulations governing the classification of corporate debt, for Bloomberg BNA’s Daily Tax Report.


Douglas Nakajima of Marcum LLP looks at the operation of the IRS proposed rules (REG-108060-15) that would allow related-party corporate debt to be reclassified as ....




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