- Federal Tax
- International Tax
- Tax Controversy & Litigation
- Financial Services
- Mergers & Acquisitions
- Insurance Finance
- Insurance Products
- Insurance M&A and Demutualizations
- Insurance Taxation
|Contact Info||Telephone: 202.383.0264|
|University ||University of Wisconsin-Madison, B.S., Chemistry|
|Law School||University of Notre Dame Law School, J.D. Symposium Editor, Notre Dame Law Review; Georgetown University Law Center, LL.M. in Taxation, with distinction|
|Admitted||2003, Georgia; 2008, District of Columbia|
American Bar Association, Tax Section
Federal Bar Association, Tax Section
District of Columbia Bar, Tax Section
State Bar of Georgia, Tax Section
William Pauls provides innovative solutions to a broad array of complex federal tax issues faced by insurers, reinsurers, and other multinational corporate clients. With more than a decade of transactional planning experience, William regularly advises clients with respect to structuring and implementing corporate reorganizations, stock and asset acquisitions and dispositions, cross-border transactions, spin-offs and other corporate separations, internal restructurings, reinsurance transactions, and captive insurance company arrangements. William also offers clients critical analysis concerning the application of the consolidated return regulations and the resolution of multifaceted international tax issues, including the application of the Foreign Account Tax Compliance Act (FATCA), the dual consolidated loss rules, and the insurance provisions of Subpart F. Before joining Sutherland, William served as a law clerk for the Honorable Mary Ann Cohen of the United States Tax Court. William leverages this experience while representing clients before the Internal Revenue Service and in federal courts. In addition to handling federal tax controversies, William's practice before the Internal Revenue Service includes obtaining letter rulings that address consolidated return issues, corporate transactional matters, and international tax questions.
Sutherland advises The Hartford in strategic sale of its life insurance business.
Sutherland serves as tax counsel to TE Connectivity Ltd. in $2 billion acquisition of Deutsch Group SAS.
Sutherland represents Manulife in restructuring U.S. operations.
Honorable Mary Ann Cohen, U.S. Tax Court
Documents by this lawyer on Martindale.com
Tax Court Holds that Residual Value Insurance Qualifies as Insurance for Tax Purposes
Dennis L. Allen,Thomas A. Gick,Michael R. Miles,Mary E. Monahan,William R. Pauls, September 24, 2015
On September 21, the United States Tax Court held in favor of the taxpayer in R.V.I. Guaranty Co., Ltd. and Subsidiaries v. Commissioner, 145 T.C. No. 9 (2015). The court concluded that the residual value insurance policies issued by RVI1 qualify as insurance policies for U.S. federal income tax...
First Investor Control Case Since 1984 Is Released
Dennis L. Allen,Thomas A. Gick,Jeffrey H. Mace,Michael R. Miles,William R. Pauls, July 7, 2015
On June 30, the Tax Court released Webber v. Commissioner, 144 T.C. No.17, in which the court upheld and applied the principles set forth in the Internal Revenue Service’s (IRS) “investor control” rulings, concluding that for federal tax purposes, the taxpayer in question was the...
IRS Releases Favorable Private Letter Ruling on “Taxable Annuity.”
Dennis L. Allen,Thomas A. Gick,Jeffrey H. Mace,Michael R. Miles,William R. Pauls, April 16, 2015
On April 10, the Internal Revenue Service (IRS) released PLR 201515001 (Oct. 10, 2014), favorably addressing a “taxable annuity” - essentially, a deferred annuity contract supported, in part, by subaccounts, each of which invested solely in a single publicly available mutual fund. Not...
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