Overview

Anthony Pastore is an associate in Mayer Brown’s Chicago office and a member of the Tax Controversy & Transfer Pricing practice.

Since joining the firm in 2013, Anthony has represented corporate, partnership, and individual taxpayers in all stages of federal tax controversy, including examination, administrative appeal, litigation, and trial. He has experience with transfer pricing allocations, debt-equity characterization, valuations, substance-over-form arguments, and penalties.

Anthony focuses a significant portion of his practice on tax disputes involving major discovery 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 large document requests from taxing authorities.

As a complement to his controversy practice, Anthony counsels multinationals on the transfer pricing of related-party transactions. He is a regular contributor to Best Methods, Mayer Brown’s blog on transfer pricing issues.

Highlights
Tax Controversy Team of the Year

Experience

  • 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).

Education

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

Admissions

  • Illinois

Court

  • US Tax Court
  • US District Court for the Central District of Illinois