Michael Liu advises and counsels multinational corporations with domestic and international tax planning. His clients span a variety of industries, including those in the high technology, semiconductor, software, pharmaceuticals, and biotechnology sectors. Before joining Morgan Lewis, he was a partner in the tax practice of another global law firm, based in Palo Alto. Michael is admitted in California only, and his practice is supervised by Illinois Bar members.
Michael advises public and private companies on a wide range of issues, including tax planning involving the use, transfer, and deployment of intangibles and intellectual property; supply chain and distribution planning; cross-border transfer pricing issues; foreign tax credit planning; redomiciliations and redomestications of both US and foreign corporations; tax-efficient cash repatriation strategies; post-acquisition integration planning and implementation; cross-border merger and acquisition transactions; and loss utilization planning.
Since the enactment of the Tax Cuts and Jobs Act (TJCA) (US tax reform), Michael’s practice has also focused on advising and counseling clients on the Section 965 “repatriation tax;” the Global Intangible Low-Taxed Income (GILTI) and Foreign Derived Intangible Income (FDII) rules; the Base Erosion Anti-Abuse Tax (BEAT) rules; and the Section 245A (dividend) participation exemption.
Michael frequently speaks and writes on international tax topics. He is a co-author of the “Foreign Corporations and Foreign-Source Income” chapter of Bittker & Eustice: Federal Income Taxation of Corporations & Shareholders (7th edition), a leading treatise covering income taxation of corporations and shareholders.
New York University School of Law, LL.M., Taxation
University of San Diego School of Law, J.D.
University of California, Los Angeles, B.S., Microbiology
University of California, Los Angeles, B.A., Philosophy
Awards and Affiliations
Recommended, Tax: US taxes: contentious; Tax: US taxes: non-contentious, The Legal 500 US (2019)
Member, Tax Authority: International Editorial Advisory Board, Law360 (2019)
Board Member, Asian Law Alliance (San Jose, California) (2016–present)