Strategic Research Sponsor of the American Bar Association's Section of International LawThe Queen's Award for Enterpise 2012

James P Fuller
Office:
Silicon Valley Center
801 California Street
94041
City:
Mountain View
State:
California
Country:
USA
Tel:
+1 650 335 7205
Fax:
+1 650 919 0942

Questions and Answers:

Who's Who Legal Thought Leaders: Corporate Tax

Jim’s practice consists of international tax planning, US federal tax dispute resolution (including at the IRS Exam and Appeals levels and in court) and large-corporate domestic and international transactions including inversions. His clients are all large US and foreign-based corporations. Jim and his firm have represented six of the Fortune 500’s top ten and over 50 of its top 100 largest corporations in US federal tax matters.

What first motivated you to become a corporate tax lawyer?

Early on, I found tax most rewarding. It’s needed up front and early in transactions and other matters to structure and to properly guide the planning or transaction.

What is the most memorable matter that you have worked on?

There have been so many. Three notable ones are Chrysler’s sale of its European operations to Peugeot (at 35 years old I was in Paris and Madrid to implement a structure that I’d designed for client Chrysler); Apple’s transferpricing arbitration in the US Tax Court, the first ever such arbitration and it was highly successful; and Eaton’s acquisition inversion of Cooper.

What would you say are the greatest challenge currently facing the sector?

Dealing with the damage wrought by BEPS as those rules are implemented in various forms in many different countries; and also with EU countries and their activist European Commission.

How does Fenwick & West LLP distinguish itself in the market?

We’re always current; always working on cutting-edge tax planning and transactions; always creative; and always practical. These might sound like platitudes but the size of our corporate client base proves the point.

What skills make a successful corporate tax lawyer?

The willingness to work very hard, to stay current, to be creative, and to be practical.

Have certain jurisdictions become more active over the past twelve months? If so, how is your firm attempting to attract clients there?

China and India always seem to present developing challenges. Working with eminent counsel in those countries has been very helpful. The EU, with its activist Commission, could be added to the list.

How important is it to be able to provide a coordinated service across offices and countries, and how does your firm achieve this?

It is very important. We work with top tax advisers in all developed countries on a regular basis. When foreign counsel is good, it’s easy.

What advice would you share with other practitioners who hope to one day be in your position?

Work hard, and always always work on those skills.

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Nominees have been selected based upon comprehensive, independent survey work with both general counsel and private practice lawyers worldwide. Only specialists who have met independent international research criteria are listed.

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