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Anthony D. Cipriano

Partner

Anthony D. Cipriano advises US, non-US, and multinational companies on the application of US federal income tax laws to their commercial and intercompany operations. Tony specializes in the taxation of technology and intellectual property (IP) transactions, including software, SaaS, and digital assets such as cryptocurrency, tokens, and NFTs. Tony advises clients on the tax efficient planning and execution of technology transactions and represents clients in US Internal Revenue Service (IRS) civil examinations.

Tony has more than 20 years of experience as a US federal income tax legal advisor, including in-house positions 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 and subject to frequent change, and common business transactions may be subject to alternative characterizations with materially different tax consequences. The rapid development of new technology products and services has created a challenging environment for applying outdated tax characterization, sourcing, and compliance rules. Tony specializes in navigating these challenges for clients.

Tony regularly lectures for professional and industry groups and events (including TEI) on various topics relating to the taxation of corporate, domestic, and cross-border transactions.

Recent client matters include:

  • Characterization of a non-US corporation’s cloud-based app services to US customers
  • Application of tax sourcing rules to a US corporation’s software product sales
  • Determining whether a non-US corporation’s server functions and related activities create a taxable presence in the United States
  • Tax planning for the formation of US or non-US corporate subsidiaries to conduct token issuances
  • Tax planning for cross-border intangible property transactions and repatriations
  • San Diego State University, 1999, B.A., Summa Cum Laude
  • University of Washington School of Law, 2002, J.D., With Honors
  • Washington
  • US Court of Appeals for Ninth Circuit
  • US Tax Court

Morgan Lewis Seattle Office 2023 Pro Bono Award

Outstanding Volunteer, Low Income Taxpayer Clinic, The Justice & Diversity Center of the Bar Association of San Francisco (2018)

Member, San Francisco & Silicon Valley Tax Firm of the Year, International Tax Review (2018)

Member, Practice Group of the Year, Tax, Law360 (2017)