Mr. Michael F. Patton

Partner, DLA Piper

Mike Patton is a partner in DLA Piper's Los Angeles Tax practice. He has assisted many multinationals in resolving IRS or foreign tax authority transfer pricing and other tax disputes. He obtained the world's first Advance Pricing Agreement and has assisted clients in negotiating more than 100 APAs. 

Mr. Patton was previously an attorney in the IRS Chief Counsel's Office where he had national responsibility at IRS for technical issues, regulations and litigation of cases relating to transfer pricing. Mr. Patton was editor of and a major contributor to the Treasury/IRS Transfer Pricing White Paper. The White Paper laid the theoretical groundwork for the profit-based transfer pricing methods adopted by the US and the OECD.

Mr. Patton has been named one of the Best of the Best US transfer pricing advisors by Euromoney and the Legal Media Group. He is the author of the Bloomberg Tax Management tax portfolio Transfer Pricing: Advance Pricing Agreements.