A Partner with DLA Piper, Mike Patton focuses his practice on international transfer pricing.
Mike has assisted many multinational corporations in a variety of industries in resolving IRS or foreign tax authority transfer pricing and other tax disputes, as well as in planning major cross-border transactions.
Mike was instrumental in obtaining the world’s first Advance Pricing Agreement (APA) and he has assisted clients in negotiating more than 100 APAs. He has also been active in resolving disputes for clients in Examination, Appeals and Competent Authority procedures.
Mike was an attorney in the IRS Chief Counsel's Office for 15 years. He had national responsibility at IRS for technical issues, regulations and litigation of cases relating to transfer pricing. Mike was editor of and a major contributor to the Treasury/IRS Transfer Pricing White Paper. The White Paper laid the theoretical ground work for the profit-based transfer pricing methods adopted by the US and the OECD, established principles for implementing R&D cost sharing arrangements, set forth guidelines for applying US "commensurate with income" adjustments and made recommendations for transfer pricing documentation and penalty provisions that have been adopted in over 40 countries. He was the lead US Treasury negotiator in many negotiations with foreign governments and US possessions for tax information exchange agreements.
J.D., University of Maryland, with honors
LL.M., Taxation, Georgetown University Law Center
B.A., University of Maryland
Bloomberg BNA Tax Management Portfolios:
890 T.M., Transfer Pricing: Alternative Practical Strategies (co-author)
Michael Patton is a member of the Bloomberg BNA Tax Management Transfer Pricing Advisory Board.
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