Michael F. Patton
Senior CounselMike 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.
- J.D., University of Maryland
Order of the Coif
with honors - LL.M., Taxation, Georgetown University Law Center
- B.A., University of Maryland
Awards
Insight Overview
Mike is an editorial advisory board member of Tax Management, Inc. and is the author of the BNA portfolio Treatment of Advance Pricing Agreements. He writes frequently for the Tax Management International Journal, the Transfer Pricing Reporter and other publications. BNA chose Mike as a featured author.
Mike was the keynote speaker at the First Kyoto International Tax Seminar, and he is a frequent lecturer at seminars and symposia on transfer pricing and other issues.
Bylines
Seminars
- Panelist, "BEPS in Action," TEI-SJSU High Tech Tax Institute, Palo Alto, November 7, 2016
- Panelist, "Base Erosion & Profit Shifting," UC Hastings Business Law Journal Tax Symposium, April 1, 2016
- Presenter, "2015 Outlook for OECD/BEPS," TEI Los Angeles Chapter - International Tax Seminar, Los Angeles, September 25, 2015
- Co-Presenter, "The Altera Decision and the Immediate Impact on Multinational Companies with CSAs and SBC,"' TEI Los Angeles Chapter - International Tax Seminar, Los Angeles, September 25, 2015
Prior Experience
