Anthony Pastore is a partner in Mayer Brown’s Chicago office and a member of the Tax Controversy & Transfer Pricing practice.
Tax Controversies. Since joining the firm in 2013, Anthony has represented corporate, partnership, and individual taxpayers in all stages of tax controversy, including examination, administrative appeal, litigation, and trial. Major trial or litigation matters include a partnership case involving the tax treatment of a leveraged partnership transaction, a transfer pricing case involving over $3 billion in section 482 allocations, and a debt-equity case involving over $9 billion in interest deductions. He has also represented clients in disputes over valuations, accounting method changes, substance-over-form arguments, and penalties.
Anthony has significant experience with complex discovery, privilege, and document-production issues. He has advised on every phase of the discovery lifecycle, from document collections through motions practice. For clients under audit, he has advised on sophisticated techniques for responding to document requests from US and foreign taxing authorities. He has co-authored chapters of Mayer Brown’s Electronic Discovery Deskbook, published by the Practicing Law Institute.
Transfer Pricing. Anthony regularly counsels multinationals on the transfer pricing of related-party transactions, including cost-sharing arrangements and transfers of intangible property. In so doing, Anthony draws on his controversy experience to anticipate potential sensitivities and legal arguments. He is a co-editor and a regular contributor to Best Methods, Mayer Brown’s blog on transfer pricing law and policy.
Areas of Focus
- Hyatt Hotels Corp. v. Commissioner, T.C. Docket No. 13858-17 (tax consequences of customer loyalty program).
- Tribune Media Co., et al. v. Commissioner, T.C. Docket Nos. 20940-16 and 20941-16 (tax treatment of leveraged partnership transaction).
- Guidant LLC, et al., v. Commissioner, T.C. Docket Nos. 5989-11, 5990-11, 10985-11, 26876-11, 5501-12, and 5502-12 (IRC § 482 reallocations).
- Tyco Electronics Corp., et al. v. Commissioner, T.C. Docket Nos. 16651-13, 16652-13, 16653-13, 16654-13, 16655-13, 16656-13, 16657-13, 16658-13, 16659-13, 16660-13, 16661-13, 16662-13, 16663-13, 16664-13, and 19556-13 (debt-equity characterization).
June 212022Chambers Global Practice Guides
The University of Chicago Law School, JD, with honors
Topics and Submissions Editor, Chicago Journal of International Law
Cornell University, BA, summa cum laude
Phi Beta Kappa
- US Court of Appeals for the Seventh Circuit
- US Tax Court
- US District Court for the Central District of Illinois
- Trustee, Taxpayers’ Federation of Illinois
- Member, Sedona Conference Working Group 1 (Electronic Document Retention & Production)