For over a decade, Anthony Pastore has advised clients facing high-stakes tax controversies. He represents clients in pre-audit planning, examination, administrative appeal, litigation, trial, and appellate review.

Anthony's experience includes the litigation, trial, and appeal of major corporate and partnership cases involving hundreds of millions or billions of dollars in tax liability. At trial, Anthony has first-chaired witness examinations, argued motions, and managed teams of attorneys. He has particular expertise with litigation involving transfer pricing, debt-equity characterization, partnership issues, accounting method changes, substance-over-form arguments, and penalties.

Anthony has represented clients in all stages of administrative proceedings, including audit, summons disputes, and IRS Appeals. For clients under audit, he has advised on techniques for responding to complex document requests from US and foreign taxing authorities.

Anthony regularly counsels multinationals on the transfer pricing of related-party transactions, including cost-sharing arrangements and transfers of intangible property. In doing so, Anthony draws on his controversy experience to anticipate potential sensitivities and legal arguments. He is a co-editor and a regular contributor to Best Methods, Mayer Brown's blog on transfer pricing law and policy.