Michael Solomon brings more than 35 years of experience in tax planning and associated business structuring. He has also handled significant controversy and litigation matters in judicial and administrative forums at the state and federal levels.
Michael is extensively involved in many types of issues concerning domestic and international businesses. He has a broad range of domestic tax experience, including corporate acquisition and structuring issues, tax accounting, period and capitalization issues, joint ventures, research tax credit problems, section 199 planning and tax-attribute planning. His international tax experience has been equally broad, including matters pertaining to intercompany transfer pricing, foreign tax credits, subpart F income, treaties, tax-favorable foreign corporate structures and financing techniques, foreign acquisitions and restructurings, sourcing, intellectual property planning and tax accounting solutions arising out of the foreign operations of U.S. based multinationals.
Michael has handled significant controversy and litigation matters related to his clients’ businesses. His practice is replete with appearances in administrative forums, (e.g., IRS Exam and Appeals), and, when necessary, he litigates federal and state cases in various federal and state judicial forums. He has considerable experience in the aerospace, transportation, energy, SaaS, medical equipment, original equipment manufacturer (OEM) and finance industries and clients have included several U.S. subsidiaries with foreign parents and many U.S. multinational corporations on the Fortune 200 list.
Michael taught Venture Technology tax law as an Adjunct Professor at Boalt Hall Law School, at the University of California at Berkeley. Before moving to California, he was an Adjunct Professor in the LLM program at Georgetown University Law School teaching Income Tax Accounting. He has also served as an expert witness in corporate transaction and tax matters that are in controversy.
Prior to joining Fenwick & West, Michael was a partner at Pillsbury Winthrop Shaw Pittman LLP, and previously was a partner in the PricewaterhouseCoopers LLP Washington National Tax Services office and a former managing partner with the tax law firm of Ivins, Phillips, and Barker.