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International Tax Issues 2013

Author(s): Michael A. DiFronzo
Practice Area: International Law, Tax
Published: Jan 2013
ISBN: 9781402419331
PLI Item #: 42398
CHB Spine #: D370

Michael A. DiFronzo serves as a Principal in and leader of the International Tax Services group in the Washington National Tax Office of PwC.  In that role, Michael serves as a global resource for the firm’s international tax practice.  His practice includes all aspects of international taxation, with a particular focus on international mergers, acquisitions and restructurings and the U.S. anti-deferral rules.  He also works closely with U.S. and non-U.S. based multinationals on cross-border financing, cash repatriation and other planning issues.   

Before joining PwC, Michael was a senior executive in the U.S. Treasury Department.  He worked for the Office of Chief Counsel, Internal Revenue Service as the Deputy Associate Chief Counsel (International – Technical).  In that capacity, he had primary responsibility for the oversight of published guidance related to the taxation of cross-border investment and related issues.  Michael served in that role from 2006 - 2010.
Prior to joining the Office of Chief Counsel, Internal Revenue Service, Michael served as a partner in the Tax Department of McDermott Will & Emery LLP in Chicago, Illinois.  There he served as an international tax attorney for large U.S. and non-U.S. multinational corporations.  Michael’s work experience also includes the National Tax Office of Deloitte & Touche LLP and the Washington, DC office of Weil Gotshal & Manges LLP.

Michael received an LL.M. in taxation from New York University School of Law, a J.D. from University of Montana School of Law, and a B.S. in Accounting from Montana State University.  Michael served on the Board of International Tax Advisors and as a guest lecturer for New York University School of Law’s graduate tax program from 1999 - 2010.   Michael also served on the Board of Visitors for the University of Montana School of Law from 2006 - 2011.

Michael’s professional affiliations include the tax sections of the American Bar Association and the DC Bar Association, as well as the International Fiscal Association.  He is the author of numerous articles on cross-border tax issues and a frequent speaker.  Michael is currently a member of the District of Columbia, Illinois, Montana and Nevada bar associations and is admitted to practice before the United States Tax Court.  He is also licensed as a CPA.