William E. Bonano

He frequently advises foreign companies involved in investing in the U.S. and U.S. companies concerning structuring operations outside of the U.S.  He also frequently advises clients concerning cost sharing, cross-border IP transfers, and treaty Competent Authority proceedings.  Bill also has considerable experience with inbound investment from Japan and China. Finally, Bill has successfully resolved a number of very large employment tax matters.

• Assists clients in obtaining Advance Pricing Agreements and in Competent Authority proceedings.
• Extensive experience in counseling taxpayers concerning compliance with FATCA, tax shelter regulation requirements and in defending clients under audit for international and domestic issues.
• Planning practice includes assisting clients in developing global transfer pricing strategies; drafting inter-company tangible property, intangible property, services and cost sharing agreements; developing section 6662 documentation; and providing advice concerning technology transfer, permanent establishment, debt vs. equity, foreign withholding, research credit, intermediate sanctions and tax accounting issues.
• Wide-ranging experience in foreign account reporting compliance matters.

• Cases Litigated

  • Claymont Investments, Inc.,  v. Commissioner, T.C. Memo. 2005-254 (2005), 90 TCM (CCH) 462 (2005).   
  • DHL Corporation v. Commissioner, T.C. Memo. 1998-461, 76 TCM (CCH) 1122 (1998), aff’d in part, rev’d in part and rem’d 285 F.3d 1210 (9th Cir. 2002).
  • National Semiconductor Corp. v. Commissioner of Internal Revenue, T.C. Memo. 1994-195, 67 TCM (CCH) 2849 (1994).
  • Seagate Technology Corp. v. Commissioner, 102 T.C. 149 (1994).
  • Intel Corp. v. Commissioner, 100 T.C. 616 (1993).
  • Apple Computer v. Commissioner, Docket No. 21781-90 (1993) (section 482 "baseball" arbitration).
  • Apple Computer, Inc. v. Commissioner, 98 T.C. 232 (1992).
  • St. Jude Medical, Inc. v. Commissioner, 97 T.C. 457 (1991).
  • National Semiconductor Corp. v. Commissioner, T.C. Memo. 1991-81, 61 TCM (CCH) 2005 (1991).
  • Southern Pacific Transportation Co. v. Commissioner, 90 T.C. 771 (1988).
  • Esmark, Inc. v. Commissioner, 90 T.C. 171 (1988).
  • Estate of Little v. Commissioner, 87 T.C. 599 (1986).
  • Johnson v. Commissioner, 78 T.C. 882 (1982).
  • Karme v. Commissioner, 73 T.C. 1163 (1980).

  • La Fargue v. Commissioner, 73 T.C. 40 (1979).

  • Soelling v. Commissioner, 70 T.C. 1052 (1978).

  • Marcos v. Commissioner of Internal Revenue, T.C. Memo. 1994-528, 68 TCM (CCH) 1002 (1994).
  • Bail Bonds by Marvin Nelson, Inc. v. Commissioner, T.C. Memo. 1986-23, 51 TCM (CCH) 294 (1986).
  • Gellatly v. Commissioner, T.C. Memo. 1984-262, 48 TCM (CCH) 108 (1984).
  • Gellatly v. Commissioner, T.C. Memo. 1984-263, 48 TCM (CCH) 111 (1984).
  • John J. Wells, Inc. v. Commissioner, T.C. Memo. 1984-79, 47 TCM (CCH) 1114 (1984).
  • Olson v. Commissioner, T.C. Memo. 1982-390, 44 TCM (CCH) 431 (1982).
  • Mertz v. Commissioner, T.C. Memo. 1979-197, 38 TCM (CCH) 823 (1979).
  • Hahn v. Commissioner, T.C. Memo. 1979-429, 39 TCM (CCH) 372 (1979).
  • Herrera v. Commissioner, T.C. Memo. 1979-345, 38 TCM (CCH) 1354 (1979).
  • White v. Commissioner, T.C. Memo. 1978-291, 37 TCM (CCH) 1226 (1978).

• Honors & Awards
  • Best Lawyers (published by BL Rankings LLC), Litigation & Controversy – Tax (2011 – 2024) and Tax Law (2008 – 2024)
  • Best Lawyers in America, Lawyer of the Year Litigation & Controversy Tax – San Francisco (2014)
  • The Legal 500 U.S., Tax Controversy, Domestic Tax (2008, 2010 – 2015), Tax – Contentious (2016 – 2017), Tax – Non-Contentious (2017).
  • Chambers USA, Tax Controversy—National (2007 – 2014)
  • Tax Disputes/Controversy Leaders' Guide, International Tax Review (2011)
  • World Tax Directory, Transfer Pricing, International Tax Review (2007)
  • Super Lawyers (2004 – 2007, 2009 – 2012)
• Associations
  • American Bar Association
  • International Fiscal Association

• Seminar Papers, Presentations & Publications
  Bill is a frequent speaker at professional seminars concerning tax controversy, transfer pricing and international tax matters, and he has published a number of articles on these topics. He is the author of the chapter on transfer pricing litigation in the Practical Guide to Transfer Pricing, published by Tax Analysts.
  • “Investment Management Compliance Issues.” ABA Section on Taxation, Fall Meeting, San Francisco, September 21, 2013
  • “Planning for the Section 199 Audit.” Tax Executives Institute, San Francisco, February 25, 2008
  • “Handling IRS Audits & Resolving Federal Tax Controversies—Initial Contact and Opening Conference.” Atlas Conference, San Francisco, September 19, 2006
  • “Reliance on Professional Advice as a Defense to Penalties.” Presentation to San Francisco Bar Association, Barristers Club, October 6, 2005
  • “Large-Case Controversy Matters - Recent Developments.” Tax Executives Institute, Orange County Chapter, April 4, 2001, Santa Ana, Calif.
  • “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, Calif.
  • “Rule 124 Arbitration.” New York City Bar Association - Resolving Taxpayer Disputes: Mediating and Arbitrating with the IRS, January 10, 2000, New York
  • “Transfer Pricing Issues.” Tax Executives Institute, Inc.- San Diego Chapter, November 16, 1999, San Diego
  • “Transfer Pricing Update ‘99.” INFONEX, June 23, 1999, Toronto
  • “DHL and BNA - An Alphabet Soup Attack.” The Appeals Alternative International Tax Forum, May 18, 1999, Marina Del Rey, Calif.
  • “Intangibles.” Global Education Services--Section 482 Transfer Pricing, December 2, 1998, San Francisco
  • “How to Manage the Transfer Pricing Examination and Avoid Penalties.” Transfer Pricing in Latin America, January 26 1998, New York
  • “Intangibles.” Global Education Services, Section 482 Transfer Pricing, December 1, 1997, San Francisco
  • “Transfer Pricing Issues for “Medium Corp.” Tax Executives Institute - Santa Clara Chapter, November 19, 1996, Santa Clara, Calif.
  • “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
  • “Last Call—Transfer Pricing Documentation: A Practical Guide to the Contemporaneous Documentation Required for 1994 Returns.” August 3, 1995, San Jose, Calif.
  • “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, DC
  • “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
  • “Handling Transfer Pricing Audits.” Sixth Annual ITI and USC International Tax Conference Current Issues in Cross Border Tax Planning, February 2, 1995, Los Angeles
  • “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
  • “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, Calif.
  • “Litigation Under the Final Section 482 Regulations.” NFTC/Georgetown University Law Center Transfer Pricing Seminar, September 28, 1994, Washington, DC