Paul DiSangro

Paul DiSangro is a trusted advisor to CFOs and tax directors in San Francisco and Silicon Valley. He has 20 years of broad experience across a range of industries including software, technology, financial services (including fintech), insurance, energy, media, pharma, biotech and retail. He prides himself on delivering value with practical solutions.

Paul draws on his decades of experience to address industry-wide issues and develops innovative solutions for emerging and unique problems. He obtains favorable results in a timely manner by partnering with clients to develop a clear strategy for navigating the thorny tax, legal and business challenges that arise as companies grow.

He is attuned to the primary concerns of management, including financial statement soundness, cash flow optimization and flexible and efficient tax and business structuring.  Paul’s experience includes:

• Optimizing benefits under the Tax Cuts and Jobs Act (including strategies to reduce the corporate tax rate of 21% down to 13% or 10.5% through incentivized structuring)
• Independent contractor structuring to benefit companies and workers
• Employment tax and fringe benefit planning and defense
• Transfer pricing, cost sharing and the movement and licensing of intangible property
• Managing general corporate issues involving worthless stock, bad debt, reorganizations and deemed dividends
• Resolving offshore account and other voluntary disclosure matters for individuals and corporations

Paul is recognized as a leading tax controversy adviser in the International Tax Review 2017 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.

Education :

• Georgetown University Law Center, LLM in Taxation, with distinction
• University of Miami School of Law, JD, magna cum laude
• Georgetown University, BA, magna cum laude

Admissions :

• California
• US Tax Court
• US Court of Federal Claims

Activities :

• San Francisco Tax Club (member and former president)
• State Bar of California, Taxation Section

Experience :

• Bare Escentuals, Inc. v. Commissioner, Tax Court Docket No. 030729-15 (deduction for domestic production activities; settled in 2017).
• 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).
• 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. 1990) (NOL computations for life and non-life insurance groups).