David H. Shapiro

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David H. Shapiro is a principal in the international tax practice of PwC, and is resident in the firm’s Washington National Tax office.  His practice focuses on the federal tax rules applicable to financial transactions executed by investment funds, multinationals and their controlled foreign subsidiaries. 

With respect to his multinational client base, David typically advises on the domestic and subpart F treatment of debt issuances and restructurings, as well as transactions executed to manage currency, commodity and interest rate risk.  With respect to investment funds, he advises on all tax aspects of financial derivatives and debt, in the alternative and mutual fund environments.  He also advises foreign “inbound” investors with respect to unique assets classes and investments in the United States.

David rejoined PwC in September 2009, after having served in the Office of Tax Policy at the United States Treasury.  As the Treasury’s Senior Counsel (Financial Products - Domestic & International), he was primarily responsible for tax issues and published guidance related to domestic and cross-border financial products and transactions. While at the Treasury, he was also heavily involved in developing tax policy, guidance and legislation surrounding the government’s response to the liquidity crisis of 2008-2009. 

Prior to joining the Treasury, David was principal in the international tax practice of PwC.  He initially joined PwC in January 2000, after having practiced tax law with Dewey Ballantine LLP. 

David is an adjunct professor of law in Georgetown University's LL.M. Program in Taxation, where he has taught a course on international tax since 2003. He actively participates on the financial transaction tax committees of the American Bar Association and the D.C. Bar Association, most recently serving as chairman of the D.C Bar committee before resigning upon his appointment to the Treasury.  He is the author of the Tax Management Portfolio on the “Taxation of Equity Derivatives,” and has also published many articles relating to the taxation of international and financial transactions.

Education:
LL.M. (Taxation), New York University School of Law (1997)
J.D., University of Virginia School of Law (1995)
A.B., Princeton University (1992) cum laude

Bloomberg BNA Tax Management Portfolios:
188 T.M., Taxation of Equity Derivatives (author)
West Virginia Corporate Income Tax