Michelle L. Andrighetto advises US and foreign-based multinationals on a wide range of federal and international tax matters, including complex transfer pricing issues, with a particular focus on cost sharing and the license of intangible property. She counsels taxpayers on the application of the Section 41 research tax credit, subpart F; GILTI; and the Section 245A deduction. She also supports clients in cross-border mergers and acquisitions, international joint ventures, internal reorganizations, and related party transactions, and assists clients with the interpretation and application of tax treaties.
Michelle has an extensive background representing taxpayers in audits and appeals before the Internal Revenue Service (IRS) and in competent authority proceedings involving US and foreign tax authorities. She regularly speaks on panels regarding the federal research and development (R&D) tax credit.
Prior to joining Morgan Lewis, Michelle was a tax associate at a national law firm, where she counseled US and foreign multinationals on a variety of complex cross-border tax issues. She previously worked as a tax director at a Big Four accounting firm, where she worked on a wide range of federal and international tax matters for private equity and hedge fund clients.
University of California, Berkeley School of Law, 1999, J.D., executive editor, California Law Review
Santa Clara University, 1996, B.S., accounting, magna cum laude
US Tax Court
US Court of Appeals for the Ninth Circuit
US District Court for the Northern District of California
Awards and Affiliations
Member, Practice Group of the Year, Tax, Law360 (2017)