Mike Patton is a partner in DLA Piper's Tax practice, based in Los Angeles. He focuses his practice on international transfer pricing.
Mike has assisted many multinational corporations in a variety of industries in resolving IRS or foreign tax authority transfer pricing and other tax disputes as well as in planning major cross-border transactions. He was instrumental in obtaining the world's first Advance Pricing Agreement and he has assisted clients in negotiating more than 100 APAs. He has also been active in resolving disputes for clients in Examination, Appeals and Competent Authority procedures.
Mike previously was an attorney in the IRS Chief Counsel's Office where had national responsibility for technical issues, regulations and litigation of cases relating to transfer pricing. Mike was editor of and a major contributor to the Treasury/IRS Transfer Pricing White Paper, which laid the theoretical ground work for the profit based transfer pricing methods adopted by the US and the OECD and established principles for implementing R&D cost sharing arrangements.
Mike has been named as one of the Best of the Best U S transfer pricing advisers as well as one of the leading Asia Pacific tax advisers by Euromoney and the Legal Media Group. He is an editorial advisory board member of Tax Management, Inc and he is the author of the BNA Portfolio treatment of Advance Pricing Agreements.
Education
JD, University of Maryland, with honours, Order of the Coif
LLM (Taxation), Georgetown University Law Center
BA, University of Maryland
Admissions
California
New York
United States Tax Court
United States Supreme Court
Practice Areas
Tax
International Tax
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