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Michael F. Patton

Michael F. Patton

Senior Counsel
Michael Patton, who leads our engagement team, combines huge technical knowledge with an ability to explain difficult issues in a simple way.
Client, The Legal 500 U.S. Taxes: Contentious

Mike Patton focuses his practice on international transfer pricing.

Mike has assisted many multinational corporations in a variety of industries in resolving IRS or foreign tax authority transfer pricing and other tax disputes, as well as in planning major cross-border transactions. 

Mike was instrumental in obtaining the world’s first Advance Pricing Agreement (APA) and he has assisted clients in negotiating more than 100 APAs. He has also been active in resolving disputes for clients in Examination, Appeals and Competent Authority procedures.

CourtsUnited States Tax CourtSupreme Court of the United States
  • J.D., University of Maryland
    Order of the Coif
    with honors
  • LL.M., Taxation, Georgetown University Law Center
  • B.A., University of Maryland


  • The Legal 500 United States
    • 2023 – Recommended, US Taxes: Contentious
      "Michael Patton, who leads our engagement team, combines huge technical knowledge with an ability to explain difficult issues in a simple way. He always follows up quickly and provides regular status updates."
    • 2022 – Recommended, US Taxes: Contentious
      Legal 500 says, "In Los Angeles, Michael Patton is a key resource regarding transfer pricing disputes and advanced pricing agreements." Clients note Michael’s "technical knowledge and confidence," as a main contributor “to a smooth performance."
    • 2021 - Recommended, US Taxes: Contentious
    • 2017 - Recommended, US Taxes: Contentious
  • International Tax Review World Transfer Pricing
    • Recognized as Highly Regarded, Transfer Pricing (2022-2024 editions)

Mike was recently recognized as a winner in the Transfer Pricing category by Corporate LiveWire at its Global Awards 2016. In addition, he was named International Transfer Pricing Advisor of the Year by ACQ Magazine at its Global Awards 2015. In addition, he has been named one of the Best of the Best US transfer pricing advisors as well as one of the leading Asia Pacific tax advisors by Euromoney and the Legal Media Group. For many years he has been named a "Highly Recommended" tax advisor by International Tax Review.

Insight Overview

Mike is an editorial advisory board member of Tax Management, Inc. and is the author of the BNA portfolio Treatment of Advance Pricing Agreements. He writes frequently for the Tax Management International Journal, the Transfer Pricing Reporter and other publications. BNA chose Mike as a featured author. 

Mike was the keynote speaker at the First Kyoto International Tax Seminar, and he is a frequent lecturer at seminars and symposia on transfer pricing and other issues.


  • Author, "Transfer pricing in the USA," Lexology, January 15, 2015
  • IRS Revises APA Procedure: Author, “Something Old, Something New; Something Borrowed, Something Blue?” Tax Management International Journal, December 11, 2015


  • Panelist, "BEPS in Action," TEI-SJSU High Tech Tax Institute, Palo Alto, November 7, 2016
  • Panelist, "Base Erosion & Profit Shifting," UC Hastings Business Law Journal Tax Symposium, April 1, 2016
  • Presenter, "2015 Outlook for OECD/BEPS," TEI Los Angeles Chapter - International Tax Seminar, Los Angeles, September 25, 2015
  • Co-Presenter, "The Altera Decision and the Immediate Impact on Multinational Companies with CSAs and SBC,"' TEI Los Angeles Chapter - International Tax Seminar, Los Angeles, September 25, 2015

Prior Experience

Mike was an attorney in the IRS Chief Counsel's Office for 15 years. He had national responsibility at IRS for technical issues, regulations and litigation of cases relating to transfer pricing. Mike was editor of and a major contributor to the Treasury/IRS Transfer Pricing White Paper. The White Paper laid the theoretical ground work for the profit-based transfer pricing methods adopted by the US and the OECD, established principles for implementing R&D cost sharing arrangements, set forth guidelines for applying US "commensurate with income" adjustments and made recommendations for transfer pricing documentation and penalty provisions that have been adopted in over 40 countries. He was the lead US Treasury negotiator in many negotiations with foreign governments and US possessions for tax information exchange agreements.



+1 310 595 3199
(Work, Los Angeles (Century City))