Will focuses on tax-efficient structuring of business transactions and corporate tax planning initiatives, particularly in the cross-border area. He supports U.S. inbound and outbound clients in solving critical tax issues, ranging from Fortune 500 companies to venture-backed and other closely held companies. He brings both significant tax planning and tax controversy experience to bear in developing and implementing defensible solutions to client problems.

During his 14 years of tax practice, Will has led the tax structuring and execution of numerous high-stakes corporate transactions, ranging from representing publicly traded corporations on mergers, acquisitions, divestitures and joint ventures, planning for legal entity rationalizations and other internal restructurings, helping U.S. multinationals optimize their foreign tax credit or subpart F positions, and advising companies and founders of non-U.S. companies on CFC and PFIC issues. Prior to entering private practice, Will clerked for the Honorable Carlos T. Bea, on the Ninth Circuit Court of Appeals.

Will has taught international taxation at Stanford Law School, UC Berkeley Law School and San José State University. He has published dozens of articles on a variety of international and corporate tax topics, including a treatise for RIA’s checkpoint catalyst, and he has spoken at over 100 industry conferences, including TEI, IFA, and Bloomberg BNA events.

  • Representative Experience
    • Advised publicly traded corporations on location of intellectual property and related sales and manufacturing functions to achieve optimal tax planning for their supply chain from a local tax, subpart F and foreign tax credit perspective
    • Defended major corporate taxpayers in leading Section 199 online software cases at the IRS audit, Appeals and Tax Court litigation levels
    • Advised, structured and negotiated complex corporate transactions, such as leveraged partnerships, tax-free spin-offs, foreign/U.S. business combinations and leveraged buyouts
    • Structured and advised on financial products, such as marketplace lending transactions, blockchain and digital assets, foreign currency hedges, convertible debt with call-spread and capped-call transactions, and variable prepaid forward contracts

Education & Admissions

J.D., with distinction
Stanford Law School

B.A., History
University of California, Berkeley

Admitted to practice in California


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