FacultyFaculty/Author Profile

Paul M. Schmidt

Baker & Hostetler LLP

Washington, DC, USA


Paul Schmidt, a former legislation counsel to the Joint Committee on Taxation, has extensive experience in corporate and international tax matters and has worked on all facets of taxation, from controversy to transactions to planning. Paul also has significant experience handling issues in connection with examinations by the Internal Revenue Service and frequently advises clients on issues raised by foreign tax authorities. Paul's practice includes representation of several Fortune 500 corporate clients in industrial, energy, and commodities businesses, as well as financial institutions in connection with international tax issues. He regularly advises private equity and hedge funds as well as publicly traded partnerships and master limited partnerships (MLPs) on tax matters and has unique knowledge of global taxable presence and transfer pricing issues facing funds. Paul regularly deals with tax issues in connection with the hospitality industry, including hotel groups, timeshares and fractional interests. He has considerable experience in hedging transactions and global hedging and trading centers. He also has worked extensively on tax issues associated with intellectual property, supply chain management, contract manufacturing, and structuring inbound and outbound global joint ventures.

Paul chairs BakerHostetler's national Tax group and is the leader of the International Tax practice team, and is a member of the firmwide Policy Committee, the firm's governing body. He is ranked in Chambers USA: America's Leading Lawyers for Business, is listed in The Best Lawyers in America© and appears on the Washington, D.C. "Super Lawyers" list. Paul is the U.S. Vice Chair of the American Bar Association Tax Section Foreign Lawyers Forum and also a member of its Government Relations Committee and formerly served as the Chair of the AICPA International Taxation Technical Resource Panel. Paul is a Certified Public Accountant in Virginia and serves as an adjunct professor of law, teaching international tax at Georgetown University.

Experience

  • Advised multinational hospitality company on international tax structuring in Asia, Europe, Australia, and Latin America, including intellectual property matters, transfer pricing, exit tax, and foreign tax credit planning. Structured tax-sharing agreement that resulted in tax attributes enabling the structuring of company's brand names and utilized holding company structures overseas. Work with the company also included representation against the IRS in an underlying tax controversy.
  • Advised U.S.-based manufacturer in connection with the structuring of tax acquisition of multinational group based in Latin America. Advised on post-acquisition integration, as well as regard for U.S. and non-U.S. tax considerations, elections, loss planning, subchapter C issues, and international tax issues.
  • Advised global private equity fund on taxation structuring issues, including transfer pricing and permanent establishment. Counseled the fund on transfer pricing controversy in India and tax assessments in Australia.
  • Advised global private equity fund client on global structuring steps in multiple jurisdictions while preparing for initial public offering and ongoing related issues, to developing a strategy for an international tax structure built to suit a particular an ongoing purpose.
  • Representing major tobacco company in connection with an IRS controversy related to a significant complicated accounting method issue.
  • Advised Fortune 50 company on potential cross-border merger transaction with third party. Performed due diligence, tax synergy analysis, U.S. tax credit analysis, U.S. subpart F analysis, tax-free reorganization analysis, inversion considerations, interest expense deductibility and interest allocation, and similar responsibilities.
  • As tax advisor to multinational manufacturing corporation based in the U.S., assisted with cross-border structuring, debt financing, international tax controversy matters, and foreign tax credit planning. Provided specific advice on company's restructuring Canadian operations and counseled with respect to a Canadian tax controversy.

Recognition

  • Chambers USA: Tax in the District of Columbia (2011 to 2015)
  • The Legal 500 United States: "Recommended Lawyer"
    • Tax - International Tax (2014, 2015)
    • Tax - Domestic tax (2015)
  • The Best Lawyers in America© (2008 to 2016)
    • Washington, D.C.: Tax Law
  • Who's Who Legal: Corporate Tax—Lawyers (2014)
  • Washington, D.C. "Super Lawyer" (2013 to 2015)

Services

  • Tax Controversy and Litigation
  • International Asset Tracing and Recovery
  • International Tax
  • Transactional Tax
  • Private Equity and Venture Capital

Admissions

  • U.S. Supreme Court
  • U.S. Court of Federal Claims
  • U.S. Tax Court
  • District of Columbia
  • Ohio

Education

  • LL.M., Georgetown University Law Center, 1997, with distinction
  • J.D., Georgetown University Law Center, 1993, magna cum laude; Editor-in-Chief, The Tax Lawyer
  • B.S., Miami University, 1989, summa cum laude
Paul M. Schmidt is associated with the following items:
Treatise Chapters  Treatise Chapters Tax Shelters: Appropriate Tax Minimization Planning and Compliance vs. Abusive Tax Avoidance Transactions and Penalties - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Tax Shelters: Appropriate Tax Minimization Planning and Compliance vs. Abusive Tax Avoidance Transactions and Penalties - The Partnership Tax Practice Series, Tuesday, August 01, 2017
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, New Brunswick , NJ
International Tax Issues 2018, Tuesday, February 06, 2018, Mechanicsburg, PA
International Tax Issues 2018, Tuesday, February 06, 2018, Pittsburgh, PA
International Tax Issues 2018, Tuesday, February 06, 2018, Philadelphia, PA
International Tax Issues 2018, Tuesday, February 06, 2018, Cleveland, OH
International Tax Issues 2018, Tuesday, February 06, 2018, Atlanta, GA
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