Joseph A. Myszka

Joseph Myszka is a partner in Baker McKenzie’s Palo Alto office. He advises domestic and international enterprises on US federal income tax issues, with a focus on resolving complex tax disputes and international tax planning. Mr. Myszka writes and speaks frequently on international tax topics, including federal tax controversy issues, transfer pricing, and foreign tax credits.

He is a co-author of the Foreign Corporations chapter of Federal Income Taxation of Corporations & Shareholders, the leading treatise covering US federal income taxation of corporations and shareholders.

Mr. Myszka advises clients at all stages of federal income tax disputes, including audit preparation and management, during administrative appeals, in alternative dispute resolution forums, and before the US Tax Court.

Mr. Myszka has extensive experience in resolving disputes involving transfer pricing, subpart F, and foreign tax credit issues. He also has significant experience advising clients on high technology tax issues, structuring international operations, cross-border transactions, and transfer pricing matters. Mr. Myszka assists clients in the high-technology, consumer products, medical device and financial service industries, among others.

Education:

• Santa Clara University School of Law (J.D.) (2008)
• Santa Clara University (M.B.A. Finance) (2008)
• University of Nevada (B.S. Business Administration and Accountancy) (2003)

Admissions:

• U.S. District Court, Northern District of California~United States (2012)
• California~United States (2008)
• U.S. Tax Court~United States (2008)

Professional Associations and Memberships:

• Certified Public Accountant – Member, State of California
• American Bar Association – Member, Section on Taxation

Representative Legal Matters:

• Nike, Inc. & Subsidiaries v. Commissioner, T.C. Docket No. 16869-16
• Nike, Inc. & Subsidiaries v. Commissioner, T.C. Docket No. 10776-15
• Represented clients in all aspects of transfer pricing disputes, including pre-audit planning, during audit, before IRS Appeals, and in litigation.
• Assisted European-headquartered software company on structuring US and global operations.
• Advised US-based multinationals with restructuring their international operations to manage subpart F exposure and foreign tax credit utilization opportunities.