William R. Skinner

650-335-7669
wrskinner@fenwick.com
Partner
Tax

William R.
Skinner

William R.
Skinner

William R.
Skinner

Partner
Tax

Will focuses his practice on international tax planning and corporate taxation, including GILTI / Subpart F, foreign tax credits, transfer pricing, tax treaties, and international restructurings and M&A. He has taught international tax as an adjunct professor at San Jose State University, the University of California, Berkeley and Stanford Law School and written numerous articles and outlines in this area. Will is also the author of a Bloomberg BNA portfolio, Controlled Foreign Corporations: Sections 959-965 and 1248. Prior to entering private practice, he clerked for the Honorable Carlos T. Bea, on the Ninth Circuit Court of Appeals.

Tax Planning

  • Advised pharmaceutical company on supply chain restructuring and opined on subpart F manufacturing exception
  • Developed cross-border intellectual property ownership structures for software for clients in the enterprise software and gaming sectors
  • Led and/or executed IP migration transactions for hardware, software, biotech and autonomous vehicle companies
  • Analyzed application of Base Erosion and Antiabuse Tax to intercompany transactions
  • Advised on internal restructurings to create and domesticate international holding companies, repatriate foreign earnings and plan for dissolution of insolvent subsidiaries

Controversy

  • Represented over a dozen major corporations at IRS Appeals on issues ranging from foreign tax credits, source of income / allocation of expense, subpart F, worthless stock loss, Section 199, withholding and tax accounting issues
  • Defended Section 199 claims at the IRS audit, Appeals and Tax Court litigation levels, including particularly those involving software

Corporate Transactions

  • Served as lead tax counsel on major tax-free deals, such as Github’s acquisition by Microsoft, Figma's pending acquisition by Adobe, Cloudera’s combination with Hortonworks and Diamond Foods’ acquisition by Snyders’ Lance
  • Advised on numerous cross-border technology company acquisitions and related IP integration planning
  • Advised marketplace lenders and their investors on effectively connected income and other financial products issues
  • Represented issuers on a wide variety of convertible note offerings, including those with contingent conversion and/or payment features and related call-spread and capped call transactions
  • Advised corporations on tax-efficient dispositions through corporate and partnership joint ventures

Tax Planning

  • Advised pharmaceutical company on supply chain restructuring and opined on subpart F manufacturing exception
  • Developed cross-border intellectual property ownership structures for software for clients in the enterprise software and gaming sectors
  • Led and/or executed IP migration transactions for hardware, software, biotech and autonomous vehicle companies
  • Analyzed application of Base Erosion and Antiabuse Tax to intercompany transactions
  • Advised on internal restructurings to create and domesticate international holding companies, repatriate foreign earnings and plan for dissolution of insolvent subsidiaries

Controversy

  • Represented over a dozen major corporations at IRS Appeals on issues ranging from foreign tax credits, source of income / allocation of expense, subpart F, worthless stock loss, Section 199, withholding and tax accounting issues
  • Defended Section 199 claims at the IRS audit, Appeals and Tax Court litigation levels, including particularly those involving software

Corporate Transactions

  • Served as lead tax counsel on major tax-free deals, such as Github’s acquisition by Microsoft, Figma's pending acquisition by Adobe, Cloudera’s combination with Hortonworks and Diamond Foods’ acquisition by Snyders’ Lance
  • Advised on numerous cross-border technology company acquisitions and related IP integration planning
  • Advised marketplace lenders and their investors on effectively connected income and other financial products issues
  • Represented issuers on a wide variety of convertible note offerings, including those with contingent conversion and/or payment features and related call-spread and capped call transactions
  • Advised corporations on tax-efficient dispositions through corporate and partnership joint ventures

  • RIA Checkpoint Catalyst, “Corporate Separations and Divisions Involving Foreign Corporations”
  • Bloomberg BNA Portfolio Author - Portfolio 6280-1st: CFCs — Sections 959–965 and 1248
  • “Assumed Contingent Liabilities in Asset Acquisitions,” Journal of Corporate Tax’n June 2022
  • “Impact of Tax Reform on Purchase and Sale of Controlled Foreign Corporations,” BBNA International Journal 2018
  • “Pre-Liquidation Dividends,” Journal of Corporate Taxation 2013
  • “Contingent Value Rights,” Journal of Taxation 2009 (selected for publication in PLI’s corporate tax practice series)

  • RIA Checkpoint Catalyst, “Corporate Separations and Divisions Involving Foreign Corporations”
  • Bloomberg BNA Portfolio Author - Portfolio 6280-1st: CFCs — Sections 959–965 and 1248
  • “Assumed Contingent Liabilities in Asset Acquisitions,” Journal of Corporate Tax’n June 2022
  • “Impact of Tax Reform on Purchase and Sale of Controlled Foreign Corporations,” BBNA International Journal 2018
  • “Pre-Liquidation Dividends,” Journal of Corporate Taxation 2013
  • “Contingent Value Rights,” Journal of Taxation 2009 (selected for publication in PLI’s corporate tax practice series)

"He's a highly sophisticated professional with a broad tax vision."

Chambers USA, Client Quote

2023 Edition