The Journey of Petterson 130

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Tax Attorney

Williams Mullen's State and Local Tax Practice Group is staffed by experienced attorneys who have practiced extensively in the state and local tax area for many years. At Thorn Law Group our legal professionals represent a diverse range of clients, including individual taxpayers, small and mid-sized businesses, partnerships, professional athletes, banks, trusts and other entities located in the United States and abroad.
Tax issues considered included consequences for the corporation and its shareholders as a result of inverting, consequences for corporation going forward (including future deductibility of interest), and strategic considerations involving public and government reactions to an inversion of this magnitude in light of significant press attention and Congressional concern regarding these transactions.

His work includes counseling clients on federal income tax planning and negotiating key tax deal points for renewable energy infrastructure and private equity transactions, internal restructurings, and mergers and acquisitions involving U.S. and non-U.S. multinational organizations.
Served as lead U.S. counsel on negotiations for bilateral advance pricing agreement that proposed a transfer pricing methodology that was new to the industry and the two treaty countries; successfully assisted the two treaty countries in reaching agreement and voiding binding arbitration in dispute spanning 14 tax years and involving intercompany transactions of more than $3.3 billion.

He has assisted clients in navigating the new international tax provisions of Global Intangible Low-Taxed income (GILTI), Base Erosion Anti-Abuse Tax (BEAT) and Foreign-Derived Intangible Income (FDII), as well as corporate conversions and the IRC 199A pass-through provisions.
Michael Caballero is a former U.S. International Tax Counsel, U.S. Treasury Office of Tax Policy, where he was responsible for some of the most important legislative, treaty-based, and regulatory projects affecting multinational corporations and financial institutions.
Lee Kelley , a former Deputy Tax Legislative Counsel at the U.S. Treasury Deputy Associate Chief Counsel (Corporate) at the IRS, led legislative and regulatory projects, including guidance that implemented codification of the economic substance doctrine.

Besides Mr. Lynam's non-docketed cases, his docketed casework includes representation for major corporations in tax-related matters including Exxon Mobil Corp.; Microsoft Tax Corp.; Washington Mutual, Inc.; Capital One Financial Corp.; Black & Decker Corp.; Veritas Software Corp.; Compaq Computer Corp.; Bravo Restaurants Inc.; and more.
We have handled matters involving all types of state and local taxes, including corporate income and franchise tax; sales and use tax; property tax litigation involving real and personal property and the tax exempt status of real and personal property; intangibles tax; excise and license taxes; and personal income tax.

Mr. Pontius has two years' experience in the international corporate tax group at KPMG in Tysons Corner, Virginia where he researched and analyzed a wide range of complex tax matters in the areas of compliance, provision, planning, and restructuring.
Michael has been recognized by Chambers USA as a leading tax attorney, with clients noting that he stands out for his persistence, accessibility, seasoned judgment and reasonableness, coupled with his creativity in finding solutions” and that he is well conne

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