William E. Bonano leads Pillsbury’s Federal Tax Controversy & Tax Policy practice. His practice focuses on international and domestic tax planning and representing taxpayers involved in federal and state controversy matters.
Bill is very experienced in handling U.S. domestic and international issue tax controversy matters, including dealing with all aspects of IRS audits, resolving hundreds of matters before the Office of Appeals and litigating over 25 matters before the U.S. Tax Court, including the only Tax Court arbitration of a transfer pricing issue.
He has extensive international planning experience, particularly in the areas of transfer pricing, FATCA compliance and foreign financial asset reporting compliance. He frequently advises foreign companies involved in investing in the U.S. and U.S. companies concerning structuring operations outside of the U.S.
He also frequently advises clients concerning cost sharing, cross-border IP transfers, and treaty Competent Authority proceedings. Bill also has considerable experience with inbound investment from Japan and China. Finally, Bill has successfully resolved a number of very large employment tax matters.
REPRESENTATIVE EXPERIENCE :
- Resolved three cycles of complex transfer pricing and other international and domestic tax issues for a major foreign multinational operating in the U.S. through an extensive subsidiary structure.
- Represented a British multinational telecommunications company with a major debt vs. equity issue involving proposed adjustments exceeding $400 million. This was one of the first instances of an IRS challenge to a multinational’s centralized cash management system.
- Represented a large U.S. staffing organization at IRS Appeals in negotiating a 95 percent reduction in significant-dollar proposed IRS income and employment tax adjustments.
- Assists clients in obtaining Advance Pricing Agreements and in Competent Authority proceedings.
- Extensive experience in counseling taxpayers concerning compliance with FATCA, tax shelter regulation requirements and in defending clients under audit for international and domestic issues.
- Planning practice includes assisting clients in developing global transfer pricing strategies; drafting inter-company tangible property, intangible property, services and cost sharing agreements; developing section 6662 documentation; and providing advice concerning technology transfer, permanent establishment, debt vs. equity, foreign withholding, research credit, intermediate sanctions and tax accounting issues.
- American Bar Association
- International Fiscal Association
- J.D., University of Washington School of Law
- B.S., California Polytechnic State University, Pomona
ADMISSIONS : Washington State, California
- U.S. Tax Court
- U.S. District Court for the Northern District of California
- U.S. Court of Appeals for the Ninth Circuit
- U.S. Supreme Court
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