Ajay C. Whittemore

Ajay C. Whittemore

San Francisco, California

Mr. Whittemore is a partner resident in the San Francisco office. His practice focuses on international tax planning and controversies. In the planning area, Mr. Whittemore advises clients in connection with both inbound and outbound matters, including tax treaty analysis, transfer pricing, tax deferral opportunities, and the architecture and implementation of tax efficient business structures. He also advises private clients in connection with pre-immigration planning, expatriation issues, foreign trust issues, investment in U.S. businesses and real estate, and global succession planning.

In the area of tax controversies, Mr. Whittemore represents clients at all stages of IRS disputes. He has extensive experience in advising clients regarding the IRS’s Offshore Voluntary Disclosure Program, as well as alternative approaches for achieving compliance with respect to foreign accounts. He also handles audits and investigations of undeclared foreign accounts. Mr. Whittemore provides compliance advice regarding interests in foreign trusts, and business entities, as well as foreign pension reporting.

Before obtaining his LL.M. in Taxation, Mr. Whittemore served for three years as a prosecutor with the State Attorney’s Office for the Nineteenth Judicial Circuit of Florida.

Areas of Practice

  • International Tax Planning
  • International Tax Controversies

Bar Admissions

  • California, 2013
  • Florida, 2005


  • New York University School of Law, New York, New York
    • LL.M. (in Taxation) - 2009
  • New York University School of Law, New York, New York
    • J.D. - 2005
  • Brigham Young University
    • B.A. cum laude - 2002

Professional Associations and Memberships

  • American Bar Association, Tax Section
  • Tax Section of the California Bar
  • Tax Section of the Florida Bar
  • San Francisco Foreign Tax Club