22 February 2011
Palo Alto, CA – Mayer Brown, a leading global law firm, announced today that Paul DiSangro has rejoined the firm as a partner in its Tax Controversy practice in Palo Alto. Previously, he was a partner and deputy practice group leader of the Global Tax group at Nixon Peabody.
“Paul is a highly regarded and prominent advisor in federal and state tax controversies and also has extensive experience advising clients on the transactions side of tax issues,” said Palo Alto partner Larry Langdon, a co-leader of Mayer Brown’s global Tax Controversy practice and a former Internal Revenue Service commissioner. “His diverse tax experience both in the US and overseas will broaden the range of services we can offer our clients in Silicon Valley and beyond.”
Mr. DiSangro concentrates his practice in federal and state tax controversies. In particular, he represents individuals and corporations in complex IRS audits, administrative appeals, “Fast Track” mediation, post-appeals mediation and tax litigation. In addition, he advises clients on a broad range of international, federal and state tax planning, as well as cross-border issues including taxation under subpart F, transfer pricing and the movement and licensing of intangible property. He also regularly advises on mergers and acquisitions and outbound and inbound investment into the United States.
“Mayer Brown is the ‘A-Team’ in the field of tax controversy, and the practice is a particular strength in Palo Alto where Larry Langdon and Cabell Chinnis are two of the top tax controversy lawyers in the country,” Mr. DiSangro said. “I look forward to working with them and the other members of the stellar Palo Alto tax team to help clients address the full spectrum of their tax-related needs.”
Prior to joining Nixon Peabody in 2008, Mr. DiSangro was a partner in the Tax Controversy practice in Mayer Brown’s Palo Alto office, which he joined as an associate in 2003 after beginning his legal career at another firm.
“Paul’s return to the Palo Alto office, along with the recent transfer of Antitrust and Intellectual Property partner Chris Kelly from our Washington, DC office, adds to our momentum and shows Mayer Brown’s commitment to grow in the Silicon Valley,” said Edward D. (Ward) Johnson, partner-in-charge of the firm’s Palo Alto office.
Mr. DiSangro’s representative cases include:
- Save Mart Supermarkets v. City of Oakland, No. RG10514461 (pending case seeking to overturn retroactive taxation of real property transfers under Measure H);
- Flextronics America, LLC v. Commissioner of Internal Revenue, Tax Court Memo 2010-245 (taxpayer victory; respecting transactions that resulted in a stepped-up 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); and
- 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).
His representative IRS audit and appeals matters include:
- Defending employers in IRS audits of employees vs. independent contractors;
- Defending transfer-pricing methodology of a major telecom company;
- Obtaining a Pre-Filing Agreement to secure more than $100 million annually in R&D tax credits for a major biopharmaceutical company;
- Advising a major international bank on compliance with Foreign Bank Account Reporting requirements;
- Defending a Fortune 200 corporation in IRS Appeals on issues involving worthless stock, bad debt, reorganizations, deemed dividends, and transfer pricing; and
- Resolving offshore account disclosure matters for individuals and corporations.
In addition, Mr. DiSangro has taught courses on international taxation in the LL.M. Tax Program at the Golden Gate Law School and has served as a faculty adviser for independent research papers on international tax issues. He frequently presents at professional tax seminars and symposia, and his articles appear in a variety of publications on current tax topics.
Mr. DiSangro received a BA from Georgetown University, a JD magna cum laude from the University of Miami School of Law and an LL.M in taxation from Georgetown University Law Center.