Übersicht

Paul DiSangro is a trusted advisor to CFOs and tax directors in San Francisco and Silicon Valley. He has 20 years of broad experience across a range of industries including software, technology, financial services (including fintech), insurance, energy, media, pharma, biotech and retail. He prides himself on delivering value with practical solutions.

Paul draws on his decades of experience to address industry-wide issues and develops innovative solutions for emerging and unique problems. He obtains favorable results in a timely manner by partnering with clients to develop a clear strategy for navigating the thorny tax, legal and business challenges that arise as companies grow. He is attuned to the primary concerns of management, including financial statement soundness, cash flow optimization and flexible and efficient tax and business structuring.

Paul’s experience includes:

  • Optimizing benefits under the Tax Cuts and Jobs Act (including strategies to reduce the corporate tax rate of 21% down to 13% or 10.5% through incentivized structuring)
  • Maximizing foreign-derived intangible income (FDII) and R&D credits
  • Minimizing global intangible low-tax income (GILTI)
  • Independent contractor structuring to benefit companies and workers
  • Stock-based compensation planning and defense
  • Employment tax and fringe benefit planning and defense
  • Dispute resolution with government agencies (IRS, FTB, BOE, EDD, CUIAB, CA Secretary of State, etc.)
  • Transfer pricing, cost sharing and the movement and licensing of intangible property
  • M&A and US outbound and inbound investment
  • Audit and due diligence readiness
  • Managing general corporate issues involving worthless stock, bad debt, reorganizations and deemed dividends
  • Managing general partnership and joint venture issues involving allocations, compliance, sales, dissolutions and the new pass-through deduction
  • Resolving offshore account and other voluntary disclosure matters for individuals and corporations
  • Tax planning for company executives

Paul is recognized as a leading tax controversy adviser in the International Tax Review 2017 Tax Controversy Leaders guide. He has authored several important works on US and international tax issues and is widely sought as a speaker and presenter at professional tax seminars and symposia. With the Tax Executives Institute, Paul organizes the annual Tax Controversy Seminar in Silicon Valley. In addition to sharing his knowledge at professional programs, he has taught international tax classes as an adjunct professor at the LLM level. Prior to joining Mayer Brown in 2003, Paul practiced in Washington DC and San Francisco with two other prominent international law firms.

Sprachkenntnisse

  • Englisch
Highlights
Tax Controversy Team of the Year

Erfahrung

  • Bare Escentuals, Inc. v. Commissioner, Tax Court Docket No. 030729-15 (deduction for domestic production activities; settled in 2017).
  • Save Mart Supermarkets v. City of Oakland, No. RG10514461 (2011) (retroactive taxation of real property transfers under Measure H).
  • Flextronics America, LLC, as Alternative Agent Pursuant to Treas. Reg. §1.1502-77A(e)(4)(ii) for C-MAC Holdings, Inc. & Subsidiaries Consolidated Group v. Commissioner of Internal Revenue, T.C. Memo 2010-24, (basis in acquired inventory).
  • United Parcel Service of America v. Commissioner of Internal Revenue, 254 F.3d 1014 (11th Cir. 2001), rev’g and remanding, T.C. Memo. 1999-268, 78 T.C.M. (CCH) 262 (1999) (vacating Tax Court’s finding on sham, assignment of income and penalties).
  • Amp, Inc. v. United States,492 F Supp 27 (Ct. Fed. Cl. 1998), rev’d by 185 F.3d 1333 (Fed. Cir. 1999) (taxpayer entitled to additional foreign tax credits).
  • Connecticut General Life Ins. Co. v. Commissioner of Internal Revenue,109 T.C. 100 (1997), aff’d by 177 F.3d 136 (3d. Cir. 1990) (NOL computations for life and non-life insurance groups).

Events

Ausbildung

Georgetown University Law Center, LLM in Taxation, with distinction

University of Miami School of Law, JD, magna cum laude, Order of the Coif; Law Review; Full scholarship

Georgetown University, BA, magna cum laude

Zulassung

Bar

  • California

Gericht

  • US Tax Court
  • US Court of Federal Claims

Berufliche Aktivitäten

  • San Francisco Tax Club (member and former president)
  • State Bar of California, Taxation Section