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International Tax Issues 2014

 
Author(s): Michael A. DiFronzo
Practice Area: International Law, Tax
Published: Jan 2014
PLI Item #: 51178
CHB Spine #: D395

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.