Deepan Patel Email and Phone Number

Practice focused on international tax, real estate and financial products. Broad experience implementing tax planning strategies to optimize business operations and minimize U.S. and foreign tax liabilities.

Provided legal advice and litigation support on tax matters involving financial institutions and the taxation of financial products including: (1) commercial banks and thrift institutions; (2) equity and debt securities, including discount and premium obligations, options, forwards, futures contracts, and other financial derivatives;(3) financial strategies, such as hedging arrangements, constructive sales, and straddles; and (4) virtual currencies;Prepared legislative proposals, treasury regulations, revenue rulings, revenue procedures, IRS notices, actions on decisions, and other public guidance related to the financial sector and capital markets; coordinated these matters with the IRS, the Treasury Department, and other government agenciesDrafted letter rulings, accounting method requests, and technical letters in response to requests from taxpayersServed on Chief Counsel’s Diversity and Equal Employment Opportunity Committee in the National Office

Two year tour with the Washington National Tax Services practice. Rotations in International Tax Services and Tax Controversy Dispute ResolutionAdvised clients on international tax matters including global structuring, mergers, acquisitions, dispositions, cross-border reorganizations, financing arrangements, intellectual property planning, tax treaties, transfer pricing methodology, permanent establishment/U.S. trade or business analysis, and international reporting/complianceNavigated clients through IRS process and procedure to facilitate compliance, drive negotiation, resolve issues, and strategize forward planning (during rotation in PwC’s National Tax Controversy Dispute Resolution practice)

Identified, designed, and implemented tax-planning strategies to optimize international operations and entity structures and minimize U.S. and foreign tax liabilities on domestic and international transactions.Developed and implemented tax-efficient cash repatriation opportunities that maximized the use of foreign tax credits and minimized withholding taxes through treaty benefitsDrafted formal tax opinions analyzing issues such as § 883 exclusions, § 304 transfers, § 367(a) and (b) transfers, § 355 distributions, § 953(d) elections, § 351 contributions, and § 475 mark-to-market accountingAnalyzed tax attributes, subpart-F income, and provisions enacted by the TCJA such as base erosion and anti-abuse tax (BEAT), global intangible low-taxed income (GILTI), and Foreign-Derived Intangible Income (FDII)Led engagement teams across multiple work streams to create high-quality deliverables in a timely mannerManaged and mentored staff by reviewing draft deliverables and providing actionable constructive feedbackEstablished a leadership role within PwC’s National Diversity and Inclusion Steering Committee to drive the performance of diverse staff and increase retention rates

Provided legal advice and guidance on the interpretation of Florida law to program areas related to employment and labor relations, collective bargaining, procurements and contracting, real estate, retirement, group insurance, information technology, data privacy, private prisons, and fleet managementRepresented the Department in litigation before all state, federal, and administrative forums

Investigated the operational processes and risk management controls of major business cycles, including financial reporting, procurement, revenue, fixed assets, treasury, HR, and payroll.Developed risk based audits, tested approach, ensured SOX compliance, mitigated risk, and communicated results to internal departments, senior management, and the audit committee

Managed a budget of over five million dollars used to fund various student programs and initiatives.