Paul DiSangro

• Exams, administrative appeals, and litigation with federal and State tax agencies
• Dispute resolution & readiness for corporate, partnership, and high-net-worth individual issues
• R&D credits and amortization
• Transfer pricing, cost sharing and the movement and licensing of intangible property
• 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
• Worthless stock, bad debt, reorganizations and deemed dividends
• Independent contractor classification
• Employment tax and fringe benefits
• Partnership and joint venture issues

Paul has 25 years of experience, and is recognized as a leading tax controversy adviser in the International Tax Review Tax Controversy Leaders guide. As leader of the federal tax team that advised on an "Impact Deal of the Year," as awarded at the International Tax Review (ITR) 2021 Americas Tax Awards, clients trust his ability to facilitate the most favorable transactions and defend them in audit. With a passion and depth of knowledge for the field, 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. Prior to joining Mayer Brown in 2003, Paul practiced in Washington DC and San Francisco with two other prominent international law firms.

Clients served by Paul include Envestnet, McKesson, General Mills, Sequoia Capital, and Bridgewater Associates.

• 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).