Paul W. Oosterhuis
International and Corporate Tax Law
Paul Oosterhuis is a senior international tax partner representing clients on a wide range of international and U.S. tax matters. Mr. Oosterhuis has extensive experience in international mergers and acquisitions, post-acquisition integration transactions, spin-offs, internal restructurings and joint venture transactions. He also represents multinational companies in nontransactional international tax planning and IRS controversy matters.
In recent transactions, Mr. Oosterhuis has represented:
- Endo Health Solutions in its acquisition of Paladin Labs Inc.;
- Nokia Corporation in the sale of its devices and services division to Microsoft;
- Theravance Inc. in the spin-off of its drug development business;
- Pfizer, Inc. in the spin-off of Zoetis, its animal health business, into a separate publicly traded company via an initial public offering; and
- Gilead Sciences, Inc. in its acquisition of Pharmasset, Inc., a transaction that was recognized in the 2012 Financial Times “US Innovative Lawyers” report.
Mr. Oosterhuis also has represented numerous clients in internal restructuring and post-acquisition integration efforts, including Hewlett-Packard Company, Pfizer Inc., Eli Lilly and IBM.
In addition to specific transactions, Mr. Oosterhuis regularly advises clients on international tax planning matters generally, including transfer pricing matters. He also represents clients in audits and appeals before the IRS and has negotiated, on behalf of clients, various advance pricing agreements, prefiling agreements and competent authority agreements. He also serves as outside tax counsel for the Pharmaceutical Research Manufacturers Association.
Mr. Oosterhuis has testified on international tax policy matters before congressional committees, including most recently the House Ways and Means Committee at its June 2013 hearing on “Tax Reform: Tax Havens, Base Erosions and Profit Sharing.” He was the only private practitioner testifying at the hearing.
Mr. Oosterhuis regularly has been selected for inclusion in Chambers Global: The World’s Leading Lawyers for Business, Chambers USA: America’s Leading Lawyers for Business, Tax Directors Handbook, The Legal 500 U.S., Who’s Who Legal: Corporate Tax, IFLR1000 and The Best Lawyers in America. He also was named Best Lawyers’ “2013 Washington, D.C. Litigation & Controversy — Tax Lawyer of the Year” and was included in Washingtonian Magazine’s 2013 “Best Lawyers” list.
J.D., Harvard University, 1973 (cum laude)
B.A., Brown University, 1969 (magna cum laude)
Legislation Attorney, Joint Committee on Taxation, U.S. Congress (1973-1976)
Legislation Counsel, Joint Committee on Taxation, U.S. Congress (1977-1978)
Adjunct Professor of Law, Georgetown University Law Center (1977-1983)
“Corporate Tax (Introduction),” Chambers Legal Practice Guides, 2014
“What’s in Order for Assets Crossing the Border?” Taxes, Vol. 88 No. 3, March 2010
"The Evolution of U.S. International Tax Policy - What Would Larry Say?," Tax Notes International, June 26, 2006
"Check-The-Box Planning in Cross-Border Transactions," TAXES Vol. 83, No.3, (March 2005)
Co-Author, “Structuring an Exemption System for Foreign Income of U.S. Corporations,” National Tax Journal, Vol. LIV No. 4, December 2001
“Taxing Cross-Border Combinations: Nationalistic Rules in a Global Economy,” TAXES, December 1997
"International R&D and Technology Transfer Arrangements," TAXES, December 1995
"The Cost of Deferral's Repeal: If Done Properly, It Loses Billions," Tax Notes, February 8, 1993
"Musings on Rev. Rul. 91-5 and Its Implications for Section 304 Transactions," Tax Notes, March 18, 1991
"The Export Source Rule: An Age-Old Rule with a Dubious New Interpretation," Tax Notes, June 26, 1989
Co-Author, BNA Tax Management Portfolio, Research and Development Expenditures, 42-3rd T.M. (1987)