William R. Pauls: Lawyer with Sutherland Asbill & Brennan LLP

William R. Pauls

William Pauls
Washington,  DC  U.S.A.

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Experience & Credentials

Practice Areas

  • Tax
  • Federal Tax
  • International Tax
  • Tax Controversy & Litigation
  • Financial Services
  • Mergers & Acquisitions
  • Reinsurance
  • Insurance
  • Captives
  • Insurance Finance
  • Insurance Products
  • Insurance M&A and Demutualizations
  • Insurance Taxation
Contact InfoTelephone: 202.383.0264
Fax: 202-637-3593
University University of Wisconsin-Madison, B.S., Chemistry
Law SchoolUniversity of Notre Dame Law School, J.D. Symposium Editor, Notre Dame Law Review; Georgetown University Law Center, LL.M. in Taxation, with distinction
Admitted2003, Georgia; 2008, District of Columbia

Professional Activities
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.

Selected Experience
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

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Congress Amends Section 831(b): Is This the Beginning of the End of Section 831(b) Abuses?
Dennis L. Allen,Thomas A. Gick,Michael R. Miles,Mary E. Monahan,William R. Pauls, December 22, 2015
On December 18, 2015, Congress passed and President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (Act), which made several significant amendments to section 831(b) of the Internal Revenue Code. Prior to these amendments, section 831(b) permitted an insurance company...

Allocating Section 871(m) Withholding Tax Risk: ISDA Publishes New Protocol Addressing Withholding Under Section 871(m)
Robert S. Chase,Mary E. Monahan,William R. Pauls,Amish M. Shah,Carol P. Tello, November 16, 2015
On November 2, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2015 Section 871(m) Protocol (the Protocol) that provides an efficient method to amend existing ISDA Master Agreements to address recently issued final regulations. Under Section 871(m), certain...

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...

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Office Information

William R. Pauls

700 Sixth Street NW, Suite 700
WashingtonDC 20001-3980


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