Michael A. DiFronzo serves as a Principal in the Washington National Tax Office of PricewaterhouseCoopers LLP, where he leads the international tax group for that office. In that role, Mr. DiFronzo manages a group of approximately 45 tax professionals, and he serves as a global resource for the firm’s international tax practice. His practice includes all aspects of international taxation, with a particular focus on international mergers, acquisitions and restructurings and the U.S. anti-deferral rules. He also works closely with U.S. and non-U.S. based multinationals on cross-border financing, cash management and other planning issues. Finally, Mr. DiFronzo’s practice includes client support and representation before the IRS.
Before joining PricewaterhouseCoopers, Mr. DiFronzo was a senior executive in the U.S. Treasury Department. He worked for the Office of Chief Counsel, Internal Revenue Service as the Deputy Associate Chief Counsel (International – Technical). In that capacity, he had primary responsibility for the oversight of published guidance related to the taxation of cross-border investment and related issues. Mr. DiFronzo served in that role from 2006 - 2010.
Prior to joining the Office of Chief Counsel, Internal Revenue Service, Mr. DiFronzo served as a partner in the Tax Department of McDermott Will & Emery LLP in Chicago, Illinois. There he served as an international tax attorney for large U.S. and non-U.S. multinational corporations. Mr. DiFronzo’s work experience also includes the National Tax Office of Deloitte & Touche LLP and the Washington, DC office of Weil Gotshal & Manges LLP.