Hope P. Krebs is an international tax partner and the co-chair of the firm's International Practice Group. Prior to joining Duane Morris, Ms. Krebs was a senior manager of International Tax Services for Ernst & Young LLP and, prior to that, was associated with the New York tax department of another major national law firm.

Ms. Krebs is a member of the International Fiscal Association, the International Tax Institute, the Committees on U.S. Activities of Foreign Taxpayers and Foreign Activities of U.S. Taxpayers of the Taxation Section of the American Bar Association, the Committees on U.S. Activities of Foreign Taxpayers and Financial Instruments of the Tax Section of the New York State Bar Association, the Pennsylvania Bar Association and the Philadelphia Bar Association. She is also a member of the Executive Committee and Planning Board for the annual Philadelphia Tax Conference.

Ms. Krebs is the co-author of a Bureau of National Affairs, Inc. Tax Management Portfolio titled U.S. Withholding - Foreign Persons and the author of numerous tax articles.She is a lecturer in law in the Graduate Tax Program at Villanova University School of Law and is a frequent speaker on international tax topics at tax conferences across the country. She is a board member of and Vice President of Membership for the British-American Business Council and is a member of the American-Israel, French-American and German-American Chambers of Commerce as well. Ms. Krebs is admitted to practice law in New York and Pennsylvania and before the U.S. Tax Court. She is listed in Who's Who in American Law, Who's Who of American Women and Who's Who in Finance and Industry.

Ms. Krebs is a 1992 graduate of New York University School of Law (LL.M., taxation), a 1987 graduate of Villanova University School of Law (J.D.) and a graduate of Drexel University (B.S., Business Administration).

Representative Matters

Minimizing worldwide income and withholding taxes and maximizing the use of foreign tax credits. Proposed and implemented alternative structures to accomplish numerous clients' goals of minimizing worldwide effective tax rates, while achieving business and economic objectives. Depending upon the particular foreign country involved, the type of U.S. taxpayer involved and the U.S. taxpayer's particular foreign tax credit position, worldwide tax savings have been as high as 50%.
Avoiding US anti-deferral tax rules, such as the controlled foreign corporation and passive foreign investment company regimes. Proposed and implemented minimally-intrusive modifications to manner in which client originally proposed to conduct business in foreign country so as to enable client to obtain US tax deferral on foreign earnings.
Tax advantageous structures for specific cross-border transactions and cross-border financing arrangements. Assisted foreign clients in structuring acquisitions and dispositions of US businesses to minimize US tax and reporting. Assisted U.S. clients in structuring offshore acquisitions and dispositions to maximize US tax deferral and minimize their worldwide effective tax rates by optimizing foreign tax credits and reducing foreign country taxes.
Tax efficient structuring for key employees transferred for business purposes from one country to another. Helped foreign business clients minimize their U.S. tax exposure despite frequent presence of employees and/or property in the United States by, among other things, slightly adjusting manner in which U.S. business was conducted and, when requested, assisted key employees in dealing with personal U.S. cross-border tax issues.
Utilizing related party transactions, transfer pricing, regional holding companies, tax treaties, tax havens and low-tax jurisdictions to enable clients to deploy capital around the globe in a tax-efficient manner. Assisted major foreign-owned multinationals in implementing tax efficient intellectual property holding company, resulting in savings of millions of dollars per year in worldwide taxes. Assisted clients in substantially lowering their worldwide effective tax rates by reviewing related party opportunities to maximize deductible fees paid to related foreign service providers in low-tax jurisdictions. Also, assisted client in preparing transfer pricing documentation for related party transactions, enabling client to avoid imposition of 20% and 40% transfer pricing penalties.

Professional Activities

Activities
British-American Business Council of Greater Philadelphia
- Board of Directors, 2005-present
- Vice President, Membership, 2005-present
Philadelphia Tax Conference
- Planning Board and Executive Committee, 2001-present
- Member, Executive/Advisory Committee, 2006
Co-Chair, Fifth Annual Inbound Tax Conference, "Current U.S. Tax Planning Strategies for Foreign-Controlled U.S. Companies," Council for International Tax Education, New York, New York, May 13-15, 2002
Chair, "Advanced International Taxation - Strategic Planning," Executive Enterprise Institute, Chicago, Illinois, October 17-18, 2001; October 4-5, 2000
Chair, "Introduction to International Taxation - Conceptual Bootcamp," Executive Enterprise Institute, Chicago, Illinois, October 15-16, 2001; October 2-3, 2000
Associations
International Fiscal Association
International Tax Institute
American Bar Association
- Section of Taxation
-- Committee on U.S. Activities of Foreign Taxpayers
-- Committee on Foreign Activities of U.S. Taxpayers
New York State Bar Association
- Tax Section
-- Committee on U.S. Activities of Foreign Taxpayers
Pennsylvania Bar Association
Philadelphia Bar Association

Admissions

Pennsylvania
New York
United States Tax Court

Education

New York University School of Law, LL.M. - Taxation, 1992
Villanova University School of Law, J.D., 1987
Drexel University, B.S., Business Administration, 1984