Anthony D. Cipriano

Having previously served as in-house tax counsel at Microsoft Corporation and First Solar Inc., Tony understands the challenging environment confronting corporate Finance and Tax departments. The US federal income tax laws are complex, subject to frequent change, and common business transactions may be subject to alternative characterizations with materially different tax consequences. Tony commonly works on discrete but complex tax issues for clients, allowing them to efficiently focus their resources. Examples of recent US federal income tax issues handled for clients include, whether:

• Stock of a corporate subsidiary qualifies for a worthless stock loss deduction
• Intercompany transactions constitute debt or equity
• Corporate mergers constitute tax free reorganizations
• CFC income constitutes Subpart F income
• Foreign corporation activities create a taxable presence in the US
• Foreign corporation cloud-based services create US source income