FacultyFaculty/Author Profile
David J. Sotos

David J. Sotos

PwC

San Jose, CA, USA


David is a Principal in PwC’s National Tax Services-International Tax Services practice located in San Jose. He advises and represents clients on a broad range of issues related to cross-border M&A, internal restructurings, subpart F, foreign tax credits, and value chain planning.

David joined PwC in 2012 from Skadden, Arps, Slate, Meagher & Flom LLP in Washington D.C., where he advised and represented high-wealth individuals as well as U.S. and foreign multinationals in a wide range of industries with respect to international tax planning and controversy matters, including cross-border M&A, restructuring transactions, U.S. tax treaties, subpart F, and foreign tax credits.

David also served ten years in various roles in the US government, including as an attorney advisor for the U.S. Tax Court, the IRS Office of Associate Chief Counsel - in both the Passthroughs & Special Industries and International divisions – and the International Tax Counsel’s Office of the U.S. Treasury. At Treasury and the IRS, he was involved in developing and issuing a broad array of international tax guidance, and negotiating several U.S. tax treaties. He authored the Section 1446 regulations related to partnership withholding, and was integral in the issuance of the Section 1503(d) dual consolidated loss regulations, the Section 954(d) foreign base company sales regulations, and significant Section 367 guidance related to cross-border M&A.

David is a member of the Ohio and D.C. Bar Associations, and admitted to the U.S. Tax Court bar. He often writes and speaks on international tax issues.

David received an LL.M. in Tax from the University of Florida, a J.D. from Capital University Law School (summa cum laude) and a B.S.B.A. (cum laude) from The Ohio State University.

David J. Sotos is associated with the following items:
CHB Chapters  CHB Chapters House and Senate Tax Reform Proposals Could Significantly Impact US International Tax Rules (November 28, 2017) - International Tax Issues New York City 2018, Wednesday, February 07, 2018
Web Segment  Web Segment Foreign Tax Credits and Subpart F Planning and Developments - International Tax Issues 2018, Friday, February 09, 2018
MP3 Audio  MP3 Audio Foreign Tax Credits and Subpart F Planning and Developments - Foreign Tax Credits and Subpart F Planning and Developments, Friday, February 09, 2018
Transcripts  Transcripts Foreign Tax Credits and Subpart F Planning and Developments - Foreign Tax Credits and Subpart F Planning and Developments, Friday, February 09, 2018
MP4 - Mobile Video Seg  MP4 - Mobile Video Seg Foreign Tax Credits and Subpart F Planning and Developments - Foreign Tax Credits and Subpart F Planning and Developments, Friday, February 09, 2018
On-Demand Web Programs  On-Demand Web Programs International Tax Issues 2018, Tuesday, February 13, 2018, New York, NY
Live Seminar  Live Seminar International Tax Issues 2019, Tuesday, February 05, 2019, New York, NY
Live Webcast  Live Webcast International Tax Issues 2019, Tuesday, February 05, 2019, New York, NY
PLI Grpcast-Live Web  PLI Grpcast-Live Web International Tax Issues 2019, Tuesday, February 05, 2019, Boston, MA
International Tax Issues 2019, Tuesday, February 05, 2019, New Brunswick , NJ
International Tax Issues 2019, Tuesday, February 05, 2019, Cleveland, OH
International Tax Issues 2019, Tuesday, February 05, 2019, Atlanta, GA
International Tax Issues 2019, Tuesday, February 05, 2019, Mechanicsburg, PA
International Tax Issues 2019, Tuesday, February 05, 2019, Pittsburgh, PA
International Tax Issues 2019, Tuesday, February 05, 2019, Philadelphia, PA
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