Beth L. Williams
Senior Counsel, Silicon Valley
Beth Williams focuses her practice on federal tax controversy matters and complex cross-border issues. She advises clients on all stages of U.S. federal tax controversies.
Beth represents clients in IRS audits, administrative appeals, alternative dispute resolution procedures and tax litigation before the U.S. Tax Court. She has more than three decades of experience in transfer-pricing matters involving the valuation of intellectual property and cost-sharing arrangements and cross-border services, and extensive experience with cross-border international tax and treaty issues. Beth began her career as special trial attorney for the U.S. Department of Treasury, and has 27 years in private practice.
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She has deep experience with U.S. domestic and international tax controversy issues, including transfer pricing controversy, foreign tax credit disputes, information reporting, research credits and penalty defense. Beth has resolved numerous cases before the IRS Office of Appeals and litigated high-stakes matters in the U.S. Tax Court and other federal courts. A list of representative clients is available upon request.
Before joining Pillsbury, Beth practiced at several leading international law firms and served with the IRS, where she gained valuable insights into agency processes and enforcement priorities.
Her work also encompasses preventive tax risk management, advising clients on audit readiness, compliance with evolving reporting obligations, and strategic tax planning to minimize controversy exposure.
Representative Experience
- Advised Microsemi Corporation and its subsidiaries in connection with U.S. Tax Court transfer-pricing proceedings involving intellectual-property valuation, cost-sharing arrangements, intercompany tangible-goods sales, Subpart F income and related penalties. Microsemi Corp. & Subsidiaries v. Commissioner, U.S. Tax Court, Dkt. Nos. 36721-21 and 19571-23.
- Advised Western Digital Corporation in U.S. Tax Court proceedings involving transfer pricing, Section 956 and foreign tax credit issues. Western Digital Corp. v. Commissioner, U.S. Tax Court, Dkt. Nos. 18984-18 and 4818-19.
- Advised The Coca-Cola Company in its U.S. Tax Court transfer-pricing dispute concerning the allocation of income attributable to international intellectual property. The Coca-Cola Company v. Commissioner, 155 T.C. 145 (2020).
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- Advised The Coca-Cola Company in U.S. Tax Court proceedings concerning foreign tax credits arising from taxes paid by its Mexican operations. The Coca-Cola Company v. Commissioner, 149 T.C. 446 (2017).
- Advised numerous confidential technology companies in the software, semiconductor and microprocessor industries on numerous cost-sharing and platform contribution valuation issues for initial contributions and acquisition platform contributions, with successful resolutions before IRS Appeals in dozens of matters.
- Advised confidential consulting companies on cross-border transfer pricing issues and competent authority dispute resolution.
- Represented Amazon.com Inc. and its subsidiaries in U.S. Tax Court litigation involving the valuation of a cost-sharing buy-in and the methodology for identifying intangible development costs. Amazon.com Inc. v. Commissioner, 148 T.C. 108 (2017), aff’d, 934 F.3d 976 (9th Cir. 2019).
- Represented Hewlett-Packard Company in consolidated U.S. Tax Court proceedings involving transfer pricing, Subpart F income, foreign tax credits, research credits and other domestic tax issues. Hewlett-Packard Company v. Commissioner, U.S. Tax Court, Dkt. Nos. 21976-07 and 10075-08.
- Represented Hewlett-Packard Company in a federal tax-refund action involving tax years and issues related to its consolidated Tax Court proceedings. Hewlett-Packard Company v. United States, N.D. Cal., Case No. 09-CV-02882.
- Advised VERITAS Software Corporation in U.S. Tax Court litigation concerning transfer-pricing issues arising from a cost-sharing arrangement, including the buy-in payment, technical service fees and asserted penalties. VERITAS Software Corporation v. Commissioner, 133 T.C. 297 (2009).
- Advised Linear Technology Corporation in connection with U.S. Tax Court proceedings involving ETI qualification, product-grouping and Section 199 issues. Linear Technology Corporation v. Commissioner, U.S. Tax Court, Dkt. No. 25690-07.
- Advised VFP Investments LLC in connection with U.S. Tax Court proceedings concerning a Son-of-BOSS transaction. VFP Investments, LLC v. Commissioner, U.S. Tax Court, Dkt. No. 8643-04.
Education
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J.D., University of Pennsylvania Law School, 1978
B.A., Economics and Philosophy, The Ohio State University, 1972
summa cum laude
Admissions
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California
Pennsylvania
Courts
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U.S. Tax Court
U.S. District Court for the Northern District of California