Paul DiSangro focuses his practice on resolving tax disputes with the IRS and state agencies. He obtains favorable results in an efficient time frame by partnering with clients to develop a clear strategy for navigating the thorny issues that arise in complex tax cases. Paul has more than 20 years of experience representing clients in all facets of tax controversy, including audits and administrative appeals, alternative dispute resolution and litigation.
Successfully handling a broad range of tax issues with the IRS over the years, Paul’s most recent work includes matters involving transfer pricing, cost sharing, subpart F exceptions, the R&D credit, the section 199 domestic production activity deduction, IP migration and valuation disputes, captive insurance company benefits, executive compensation, depreciation, capitalization, deductions, withholding, independent contractors vs. employees, offshore accounts, partnership issues and debt versus equity. Paul is currently litigating a section 199 issue for a mineral makeup company in the US Tax Court.
Paul also has extensive state and local tax controversy experience in California—with the California Franchise Tax Board, the California Board of Equalization, the California Employment Development Department and the California Unemployment Insurance Appeals Board—as well as with tax agencies in other states. His recent cases, which involve issues in more than 40 states, have included state transfer pricing and valuation disputes, alternative apportionment, sales and use taxes for online sales, trust and estate issues, market-based sourcing, tax shelters, independent contractors versus employees and voluntary disclosure programs.
On the tax planning side, Paul advises clients on a broad range of international, federal and state tax concerns. He counsels on cross-border issues including taxation under subpart F, transfer pricing and the movement and licensing of intangible property. He also advises on mergers and acquisitions and US outbound and inbound investment.
Paul is recognized as a leading tax controversy adviser in the International Tax Review 2016 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.