FacultyFaculty/Author Profile
David  Sotos

David Sotos

PwC

San Jose, CA, USA


David is a Principal in the Washington National Tax Services-International Tax Services practice.  David's practice focuses on international tax matters including M&A, restructuring transactions, and subpart F and foreign tax credit planning for U.S. multinational corporations.  In June 2013, David relocated to San Jose but remains part of PwC's WNTS-ITS practice.

David joined PwC in April 2012 from Skadden, Arps, Slate, Meagher & Flom in Washington D.C, where he advised and represented U.S. and foreign multinational corporations, including several pharmaceutical companies, on a broad range of international tax planning and tax controversy matters, including corporate inversions, as well as subpart F and foreign tax credit planning. 

Prior to private practice, David 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, serving in both the Passthroughs and Special Industries and International divisions, as well as the International Tax Counsel's Office of the Department of the Treasury.  While in the government, David was extensively involved in the development and issuance of a broad array of international tax guidance projects, the negotiation of several U.S. tax treaties and protocols, and the evaluation of legislative proposals.  He authored the regulations under Section 1446 relating to partnership withholding, and was integral in the modernization of the dual consolidated loss regulations under Section 1503(d) and the foreign base company sales regulations under Section 954(d), as well as significant guidance under Section 367 relating to cross-border M&A transactions.  David also represented the United States in negotiating tax treaties and protocols with Canada, Belgium, and Bulgaria, and was the lead U.S. Treasury delegate responsible in the early negotiations to obtain tax information exchange agreements with Gibraltar and Liechtenstein.    

David is a member of the American Bar Association, and the DC Bar Association, and frequently writes and speaks on international tax issues.  He is licensed to practice law in Ohio and the District of Columbia, and represent clients before the United States Tax Court. 

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

David Sotos is associated with the following items:
Web Segment  Web Segment Foreign Tax Credits and Subpart F Planning and Developments - International Tax Issues 2017, Wednesday, February 08, 2017
CHB Chapters  CHB Chapters IRS Provides Roadmap for Examining Subpart F Foreign Base Company Income Functional Analysis (February 19, 2016) - International Tax Issues 2017, Wednesday, February 08, 2017
EU Fiscal State Aid—A Briefing Document (October 15, 2014) - International Tax Issues 2017, Wednesday, February 08, 2017
Notice 2016-52 Details Section 909 Regulations for FTC Splitting Events Arising from Foreign-Initiated Adjustments Such as EU State Aid (September 19, 2016) - International Tax Issues 2017, Wednesday, February 08, 2017
Foreign Tax Credit Guidance under Section 909 Related to Foreign-Initiated Adjustments; Notice 2016-52 - International Tax Issues 2017, Wednesday, February 08, 2017
MP3 Audio  MP3 Audio Foreign Tax Credits and Subpart F Planning and Developments - Foreign Tax Credits and Subpart F Planning and Developments, Wednesday, February 08, 2017
Transcripts  Transcripts Foreign Tax Credits and Subpart F Planning and Developments - Foreign Tax Credits and Subpart F Planning and Developments, Wednesday, February 08, 2017
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, Wednesday, February 08, 2017
On-Demand Web Programs  On-Demand Web Programs International Tax Issues 2017, Monday, February 13, 2017, New York, NY
Live Seminar  Live Seminar International Tax Issues 2018, Tuesday, February 06, 2018, New York, NY
Live Webcast  Live Webcast International Tax Issues 2018, Tuesday, February 06, 2018, New York, NY
PLI Grpcast-Live Web  PLI Grpcast-Live Web International Tax Issues 2018, Tuesday, February 06, 2018, Cleveland, OH
International Tax Issues 2018, Tuesday, February 06, 2018, Philadelphia, PA
International Tax Issues 2018, Tuesday, February 06, 2018, Atlanta, GA
International Tax Issues 2018, Tuesday, February 06, 2018, Mechanicsburg, PA
International Tax Issues 2018, Tuesday, February 06, 2018, New Brunswick , NJ
International Tax Issues 2018, Tuesday, February 06, 2018, Pittsburgh, PA
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