Paul DiSangro

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Paul DiSangro

Paul DiSangro

Northern California (Palo Alto & San Francisco)

+1 650 331 2045

Overview

Paul DiSangro is a trusted advisor to CFOs and tax directors in San Francisco and Silicon Valley. He has 25 years of 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’s experience includes:

Exams, administrative appeals, and litigation with federal and state agencies
Transfer pricing, cost sharing and the movement and licensing of intangible property
Audit and due diligence readiness
R&D credits
Foreign-derived intangible income (FDII) and global intangible low-tax income (GILTI)
Section 199 Domestic Production Activity Deduction
Qualified Small Business Stock (QSBS) and tax optimization
Cross-border M&A and US outbound and inbound investment
Worthless stock, bad debt, reorganizations and deemed dividends
Independent contractor classification
Stock-based compensation
Employment tax and fringe benefits
Partnership and joint venture issues

Paul is recognized as a leading tax controversy adviser in the International Tax Review Tax Controversy Leaders guide and led the federal tax team that advised on a transaction named an “Impact Deal of the Year” by International Tax Review (ITR) at its 2021 Americas Tax Awards. 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.

Areas of Focus

Practices

Spoken Languages

English

Highlights

Impact Deal of the Year

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Experience

Represented Envestnet in the acquisition of Harvest Savings & Wealth Technologies Inc., a provider of automated goals-based saving tools and wealth solutions, from a group of private equity investors.
Advised Square Inc. on their acquisition and integration of Credit Karma’s tax software product. This transaction was named an “Impact Deal of the Year” by International Tax Review (ITR) at its 2021 Americas Tax Awards.
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. 1999) (NOL computations for life and non-life insurance groups).

Education

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

Admissions

California
District of Columbia

Court

US Tax Court
US Court of Federal Claims

Activities

Vice Chair, Tax Procedures & Litigation Committee of the California Lawyer’s Association
San Francisco Tax Club (member and former president)
San Jose State University, High-Tech Tax Institute Board Member