Anthony D. Cipriano advises multinational corporations on the application of US federal income tax laws to corporate formations, distributions, liquidations, acquisitions, and intercompany transactions. Tony provides clients with formal or informal technical tax guidance through all transactional phases—planning, implementation, and post-transaction integration and compliance. He also represents clients on transactions or matters subject to IRS civil examination, responding to IRS inquiries, and contesting proposed adjustments.
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