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William E. Bonano william.bonano @pillsburylaw.com San Francisco
50 Fremont Street Mr. Bonano's practice includes international and domestic tax planning and representation of taxpayers involved in IRS controversy matters before Examinations, Appeals and in litigation. Before joining Pillsbury Winthrop LLP, Mr. Bonano was an International Special Trial Attorney with the Office of Chief Counsel, Internal Revenue Service, in San Francisco. Mr. Bonano has significant litigation experience, having litigated twenty-five tax controversy matters, including the only Tax Court arbitration of a transfer pricing issue. A listing of cases litigated by Mr. Bonano appears below. Mr. Bonano has also represented taxpayers in summons enforcement proceedings in United States District Court and has extensive experience in representing taxpayers and resolving issues at Examinations and Appeals. Mr. Bonano's planning practice involves advising U.S. and foreign-based corporations concerning transfer pricing, cost sharing, technology transfer, section 6662 documentation, permanent establishment, debt vs. equity, foreign withholding, research credit, tax shelter registration and other international and domestic tax issues. Mr. Bonano is a frequent speaker at professional seminars concerning tax controversy, transfer pricing and international tax matters. A listing of professional seminar papers prepared by Mr. Bonano appears below. Mr. Bonano has also published a number of articles on transfer pricing and tax controversy matters, including articles discussing transfer pricing for intangible property and a chapter on transfer pricing litigation for the recently published, Practical Guide to U.S. Transfer Pricing. Professional Seminar Papers
"Section 954(e) Subpart F Service Income." Alliance for Tax, Legal and Accounting Services, Tax Planning for CFC's Under Subpart F, April 26, 2000, San Francisco, California. "Rule 124 Arbitration." New York City Bar Association - Resolving Taxpayer Disputes: Mediating and Arbitrating with the IRS, January 10, 2000, New York City, New York. "Transfer Pricing Issues." Tax Executives Institute, Inc.- San Diego Chapter, November 16, 1999, San Diego, California. "Transfer Pricing Update '99." INFONEX, June 23, 1999, Toronto, Canada. "DHL and BNA - An Alphabet Soup Attack." The Appeals Alternative International Tax Forum, May 18, 1999, Marina Del Rey, California. "Intangibles." Global Education Services--Section 482 Transfer Pricing, December 2, 1998, San Francisco, California. "How to Manage the Transfer Pricing Examination and Avoid Penalties." Transfer Pricing in Latin America, January 26 1998, New York, New York. "Intangibles." Global Education Services, Section 482 Transfer Pricing, December 1, 1997, San Francisco, California. "Transfer Pricing Issues for 'Medium' Corp." Tax Executives Institute - Santa Clara Chapter, November 19, 1996, Santa Clara, California. "Transfer Pricing Examinations." Glasser Legal Works and Fordham University School of Law Fifth Annual Transfer Pricing Institute: Problems and Solutions, February 8, 1996, San Francisco, California. "Last Call–Transfer Pricing Documentation: A Practical Guide to the Contemporaneous Documentation Required for 1994 Returns." August 3, 1995, San Jose, California. "Expert Witness Direct Examination Demonstration." Georgetown University Law Center, CLE Division, and California State Bar Tax Section Tax Litigation: Civil and Criminal, May 11, 1995, Washington, D.C. "Living with the IRS in the 90's." Counsel for International Tax Education IRS Compliance Program Resolving International Tax Controversies, February 27, 1995, San Francisco, California. "Handling Transfer Pricing Audits." Sixth Annual ITI and USC International Tax Conference Current Issues in Cross Border Tax Planning, February 2, 1995, Los Angeles, California. "Section 482 From a Litigation Perspective." World Trade Institute Tax Aspects of Intercompany Pricing, Including New IRS Section 482 Regulations, December 5, 1994, San Francisco, California. "Litigation Under the Final Section 482 Regulations." NFTC/Georgetown University Law Center Transfer Pricing Conference, November 28, 1994, Washington, D.C. "The Apple Arbitration: Arbitration of a Section 482 Issue Under Tax Court Rule 124." United States Tax Court Judicial Conference, November 16, 1994, Baltimore, Maryland. "Supporting and Defending Your Transfer Price: Audit Strategies." American Conference Institute Transfer Pricing Seminar, November 10, 1994. "Section 482 Update and Alternative Dispute Opportunities." Sixth Annual Fall Transfer Pricing Conference, Fordham University/Glasser LegalWorks, October 27, 1994. "Recent Developments in Litigation of Transfer Pricing Disputes." Tax Executives Institute, Inc. 49th Annual Conference, October 23, 1994, Orange County, California. "Litigation Under the Final Section 482 Regulations." NFTC/Georgetown University Law Center Transfer Pricing Seminar, September 28, 1994, Washington, D.C.
B.S., California State University at Pomona Affiliations
Member of: American Bar Association, International Fiscal Association Recipient of: 1992 and 1993 Special Trial Attorney Awards from the Internal Revenue Service
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