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Home | BakerHostetler

Fifth Circuit Strikes Down CTA Injunction, FinCEN Extends Deadline to Jan. 13, 2025

Bulls, Bears, and Blockchain™ – December 26, 2024

Blockchain Monitor

Weekly Blockchain Blog – December 23, 2024

What to Expect and How to Prepare: A Guide to Employing Foreign Workers in the Age of Trump

In addition to steering BakerHostetler’s strategic priorities, Paul leads by example, staying true to our mission to partner with clients and provide them with timely, responsive and high-quality solutions. He drives our culture of collegiality and inclusion, and his transformative approach to leadership has enhanced the health and welfare of personnel at all levels.

Prior to becoming firm chair, Paul spent 10 years leading BakerHostetler’s national Tax Practice Group and 16 years leading the International Tax team. He previously served as legislation counsel to the U.S. Congress Joint Committee on Taxation and was a partner at a Big Four accounting firm. This experience allowed him to hone his abilities to advocate for and motivate others and build team consensus to achieve goals.

Paul’s legal experience as a tax practitioner revolves around the needs of domestic and multinational companies for sophisticated tax counsel in two principal areas: tax implications related to transactions and controversies. He has worked with private equity clients, hedge funds and publicly traded partnerships, along with both publicly traded and privately held industrial, technology, energy, agriculture, commodities, hospitality and healthcare businesses, on all facets of taxation. Paul’s primary focus is on international taxation, and he advises clients on technical and policy issues in connection with tax reform, transfer pricing, treaties, permanent establishments, U.S. trade and business, subpart F, foreign tax credits, GILTI, FDII, BEAT, inversions, and global debt and hedging issues. He frequently advocates for clients before the Internal Revenue Service as well as at the Treasury Department and on Capitol Hill.

Most of Paul’s client matters involve confidential counseling; they are rarely publicly reported but include work for clients such as The Carlyle Group, ExxonMobil, Wyndham Hotel Group, Travel &amp; Leisure Co., Archer Daniels Midland, Lincoln Electric, STERIS, Sherwin-Williams, Parker Hannifin and the Las Vegas Sands.

Paul is a member of the Bloomberg Tax U.S. International Advisory Board, the GW/IRS Annual Institute on Taxation Advisory Board, and the Parker Fielder Oil and Gas Tax Conference Planning Committee, and previously served as the U.S. vice chair of the American Bar Association Tax Section Foreign Lawyers Forum and as chair of the AICPA International Technical Resource Panel. For more than a decade, he taught international tax as an adjunct professor of law at the Georgetown University Law Center. Paul is also a member of the Economic Club of Washington.

Paul gives back to the community by serving on the Boys &amp; Girls Club of America’s National Board of Governors since 2019 and chairs its Government Relations Committee. Paul serves on the host committee for the Mid-Atlantic Make-a-Wish Foundation Ball and also serves on the board of Bishop O’Connell High School in Arlington, Virginia.

core/freeform

LL.M., Taxation, Georgetown University Law Center, 1997, 

J.D., Georgetown University Law Center, 1993, 

B.S., Miami University, 1989, 

<ul>
<li>Washingtonian “Top Lawyers”: Tax (2024)</li>
<li>Chambers USA: Tax in the District of Columbia (2011 to 2024)</li>
<li>The Legal 500 United States (2014 to 2024)
<ul>
<li>Recommended in Tax: International Tax (2014 to 2019, 2022 to 2024)</li>
<li>Recommended in Tax: U.S. Taxes: Non-Contentious (2015 to 2022)</li>
<li>Recommended in Tax: U.S. Taxes: Contentious (2019 to 2024)</li>
</ul>
</li>
<li>Lexology Index (formerly Who&#8217;s Who Legal): Corporate Tax (2014 to 2019, 2021 to 2022)</li>
<li>BTI Client Service All-Star (2017, 2019)</li>
<li>The Best Lawyers in America®
<ul>
<li>Washington, D.C.: Tax Law (2008 to 2025)</li>
</ul>
</li>
<li>Washington, D.C., &#8220;Super Lawyer&#8221; (2013 to 2024)</li>
</ul>

Washington, D.C.

BakerHostetler to launch Austin office on Jan. 1 with addition of 10-attorney affordable housing team

Paul Schmidt, Jeff Paravano, Kenneth Reisenfeld, Justin Murphy Named to 2024 “Top Lawyers” List

BakerHostetler attorneys, practice areas stand out in The Legal 500 annual guide

Chambers USA Guide 2024 Recognizes 155 BakerHostetler Attorneys and ­66 Practice Areas

BakerHostetler Sponsors Tax Executives Institute Seminar

BakerHostetler again recognized for outstanding service in BTI’s Client Service A-Team 2024 Report

BakerHostetler Relocates Los Angeles Office to Premier Century City Space

Schmidt and Mowbray speak at Tax Executives Institute conference

Associates hired since 2020 are generally ‘not as far along’ as previous classes

Paul Schmidt says generative AI may affect law firms’ non-legal personnel in different ways

Paul Schmidt Discusses Current Client Approaches to Conserving Financial Resources

Paul Schmidt Says Attorney Engagement in Big Law Must Be Promoted

Paul Schmidt Discusses Indicators of Concern Among Clients About Economy

BakerHostetler Attorneys and Practice Areas Recognized in The Legal 500 2023 Guide

Chambers USA Guide 2023 Honors 147 BakerHostetler Attorneys and Recognizes 64 Practice Areas

Paul Schmidt Quoted About Inaugural Sponsorship of Georgetown Law’s Diversity Pipeline Program

Paul Schmidt, Jeffrey Paravano and Brian Davis Offer Washington Update at Cleveland Tax Institute; Scott Swartz Is Chair of the Event

BakerHostetler Names Katherine Lowry New CIO

Hundreds of BakerHostetler Attorneys Honored as 2023 Best Lawyers, Ones to Watch and Lawyers of the Year

Inflation Reduction Act Becomes Law

Per-Account or Per-Form Penalty?

BakerHostetler Attorneys, Practice Areas Shine in The Legal 500 2022 Guide

Chambers USA Guide 2022 Honors 145 BakerHostetler Attorneys and Recognizes 62 Practice Areas

Paul Schmidt and Eric Sagerman Interviewed on IP Team Addition

Amy Traub is honored with this year’s Women’s Committee Trailblazer Award as a fitting tribute to an inspiring firm leader.

Paul Schmidt, Mark Tidman, Mark Itri and Michael Dreznes Quoted on Big IP Add

Paul Schmidt Credits Deeper Client Ties for Record Revenue

Paul Schmidt, Brian Davis, John Lehrer, Nicholas Mowbray are Presenters at TEI Webinar Series

Paul Schmidt, Eric Sagerman, Matthew Kane, Sylvia Kim Featured in Article about BakerHostetler Growth in California

Paul Schmidt Comments on Potential Downturn for Niche Law Firms

Paul Schmidt Comments on Potential for “Irreparable Harm” from Delay in Return to Office Plans

Paul Schmidt Talks to “The American Lawyer” about Return-to-Office Options

191 BakerHostetler Attorneys Named in 2022 “Best Lawyers” List; 10 Recognized as “Lawyer of the Year”

Paul Schmidt, Ernessa McKie Discuss Pandemic-Inspired Changes to Legal Industry Culture

Paul Schmidt Optimistic About Economy, Legal Industry

Paul Schmidt: “I Love Being a Tax Lawyer”

Paul Schmidt Talks about BakerHostetler’s Approach to Return-to-Office and Remote Work Policies

Paul Schmidt Talks about Return to Office, Trends in Legal Retention and Hiring

BakerHostetler Attorneys, Practice Areas Recognized in The Legal 500 Guide for 2021

Chambers and Partners USA Honors 134 BakerHostetler Attorneys and 55 Practice Areas in 2021 USA Guide

Paul Schmidt Talks to Bloomberg Radio about Potential for New Corporate Tax Inversions

Paul Schmidt Comments on Potential for Uptick on Inversion Deals in Response to Higher Taxes

Paul Schmidt Speaking on Section 163(j) at TEI Mid-Year Conference

Paul Schmidt Points to Strategic Plan, DADM Practice and More for Firm Success

Paul Schmidt Weighs in On Return to the Workplace, Post-Pandemic Office Culture

$2 Trillion CARES Act Provides Significant Tax and Workforce Relief for Businesses, Individuals

BakerHostetler Attorneys Make Significant Gains in The Legal 500 Annual Guide

Chambers and Partners USA Honors 127 Attorneys and 43 Practice Areas in 2019 Guide

BakerHostetler Boosts High Marks in the Legal 500 2018 Annual Guide

Chambers and Partners USA Honors 118 Attorneys and 45 Practice Areas in 2018 Guide

Paul Schmidt, John Lehrer, John Bates Speak on Section 482 at International Tax Course

150 BakerHostetler Attorneys Named 2016 Super Lawyers; 91 Named Rising Stars

Schmidt, Littman, Lehrer and Dayan Address Tax Executives Institute

Five BH Attorneys Address Tax Institute

Tax Controversy and Litigation

Transactional Tax

International Tax

Private Equity

Compliance

Federal Policy

IncuBaker – Emerging Technologies

Web3 and Digital Assets

Industries

Hospitality

<h5>Planning and Transactions</h5>
<ul>
<li>Advising a non-U.S. based company on the substantial acquisition of a U.S. automobile manufacturing business, including debt financing issues, withholding tax and treaty issues, permanent establishment issues and post-acquisition integration.</li>
<li>Advising a U.S. private equity fund manager in connection with transfer pricing issues relating to certain services and cost reimbursements relating to a Chinese investment advisory structure.</li>
<li>Advising a U.S. private equity fund manager in connection with the unwind of an Australian fund.</li>
<li>Advising a U.S. private equity fund manager in connection with the unwind of a Korean fund.</li>
<li>Advised a major hospitality company in connection with restructuring a line of business in Europe in anticipation of an over $1 billion sale transaction prior to a major U.S. spin-off reorganization.</li>
<li>Advised a foreign-based manufacturing company in connection with issues related to certain intercompany restructuring transactions and the impact of new regulations issued in connection with U.S. tax reform.</li>
<li>Advised a major U.S.-based energy company on structuring considerations, including issues resulting from U.S. tax reform, in connection with certain joint venture export arrangements.</li>
<li>Advised a private equity fund on the unwind of a Brazilian fund investment structure, including advising on certain passive foreign investment company issues.</li>
<li>Advised a U.S.-based hospitality and gaming company on the impact of certain repatriation provisions, foreign tax credit provisions and interest limitations in connection with proposed regulations issued in connection with U.S. tax reform.</li>
<li>Advised a Fortune 100 company in connection with the U.S. tax issues associated with the acquisition of manufacturing operations in Belgium and the Netherlands.</li>
<li>Advised a major U.S. private equity fund in connection with its international investment advisory structure, permanent establishment issues and transfer pricing issues.</li>
<li>Provided tax analysis, tax risk-assessment, tax disclosure and tax opinions in connection with debt and equity offerings of a publicly traded oil and gas transportation company structured as a master limited partnership (MLP).</li>
<li>Provided tax structuring advice, tax accounting method advice, tax risk-assessment, tax disclosure and tax opinions in connection with the debt and equity offerings of a publicly traded oil and gas exploration and production company.</li>
<li>Advised a multinational U.S. agribusiness in connection with the disposition of a fertilizer business in Brazil and Paraguay.</li>
<li>Advised on structuring and U.S. international tax issues in connection with a joint venture for the importation of liquefied natural gas, perhaps one of the biggest transactions of its kind at the time.</li>
<li>Advised a global food processing and commodities trading corporation on several joint ventures, including a multibillion-dollar Pan-Asian commodity trading structure.</li>
<li>Provided U.S. tax and corporate advice in connection with the restructuring of a U.S.-based, publicly traded multinational company’s exchange and rentals business unit that involved five different European countries.</li>
<li>Provided U.S. tax advice in connection with the consequences of the unwinding of a joint venture related to processing commodities in Eastern Europe.</li>
<li>Provided U.S. tax advice on a several billion-dollar public acquisition of a multinational group of companies, including issues arising under the Foreign Investment in Real Property Tax Act and the passive foreign investment company regime, as well as certain unique potential consequences of the inversion legislation.</li>
<li>Advised a Fortune 25 public company with respect to structuring a cross-border oil and gas export joint venture, including addressing U.S. trade or business and effectively connected income issue, title passage and transportation tax issues related to the shipping aspects of the transaction.</li>
<li>Advised a client in connection with a global principal structure, including outbound transfer tax issues associated with a multinational agribusiness.</li>
<li>Advised a public manufacturing company in connection with a multinational acquisition, including performing international due diligence.</li>
<li>Advised a major media firm in connection with an offshore acquisition, including analyzing the effects of Sections 367 and 1248 on the seller.</li>
<li>Advised a multinational hospitality company on international tax structuring in Asia, Europe, Australia and Latin America, including intellectual property matters, transfer pricing, exit tax and foreign tax credit planning. Structured a tax-sharing agreement that resulted in tax attributes enabling the structuring of the company’s brand names and utilized holding company structures overseas.</li>
<li>Advised a U.S.-based manufacturer in connection with the structuring of the tax acquisition of a multinational group based in Latin America. Advised on post-acquisition integration, as well as with respect to U.S. and non-U.S. tax considerations, elections, loss planning, subchapter C issues and international tax issues.</li>
<li>Advised a global private equity fund on structuring and the U.S. tax implications of an exit from an investment in China, including U.S. foreign tax credit implications.</li>
<li>Advised a global private equity fund in connection with structuring the exit of an investment in Australia.</li>
<li>Advised a global private equity fund client on global structuring steps in multiple jurisdictions while preparing for an initial public offering and ongoing related issues, including developing a strategy for an international tax structure.</li>
<li>Advised a Fortune 50 company on a potential cross-border merger transaction with a third party. Performed due diligence, tax synergy analysis, U.S. tax credit analysis, U.S. subpart F analysis, tax-free reorganization analysis, inversion considerations, interest expense deductibility and interest allocation, and similar responsibilities.</li>
<li>Advised a U.S. multinational corporation on a cross-border structure in connection with Canada, including cross-border structuring, debt financing, foreign tax credit planning and repatriation planning.</li>
<li>Advised a non-U.S.-based pharmaceutical company on structuring U.S. acquisitions, operations, permanent establishment and U.S. trade or business considerations and transfer pricing issues.</li>
<li>Advised a German multinational corporation on the disposition of a line of business including its U.S. operations, as well as structuring the transaction to optimize the tax result.</li>
<li>Advised an Austrian manufacturing company on structuring a reorganization of its non-U.S. operations and U.S. operations in a manner so as to qualify for U.S. treaty benefits.</li>
</ul>
Controversy
<ul>
<li>Representing a U.S. agri-business in connection with an IRS Appeal regarding a dispute around research and experimentation credit claims.</li>
<li>Representing a U.S. farming business in tax litigation surrounding an accounting methods issue.</li>
<li>Representing a U.S. medical device company in connection with IRS Appeals of certain transfer pricing and international structuring issues.</li>
<li>Assisting a U.S.-based private equity fund manager in connection with a tax dispute with Dutch tax authorities over valuation in connection with an exit transaction.</li>
<li>Representing a foreign-based manufacturing company in connection with IRS proposed transfer pricing adjustments with respect to certain intercompany debt.</li>
<li>Representing a U.S. multinational company at U.S. competent authority and in advance pricing agreement negotiations relating to certain Canadian-initiated transfer pricing disputes.</li>
<li>Successfully resolved at IRS Appeals, with a substantial government concession, a tax controversy matter in connection with certain SEC disgorgement payments.</li>
<li>Successfully resolved at IRS Appeals, with nearly a full government concession, an IRS controversy in connection with an accounting method issue involving the proper time for an accrual basis taxpayer to take a tax deduction for an annual payment made pursuant to the master settlement agreement entered into with the 50 states with the major players in the tobacco industry.</li>
<li>Successfully resolved at IRS Appeals, with a full government concession, an IRS controversy related to international boycott provisions under Section 999 of the Code on behalf of a U.S. multinational engineering firm. Also successfully resolved a long-term contract issue in favor of the taxpayer at IRS Examination.</li>
<li>Successfully resolved at IRS Appeals, with a full government concession, an IRS controversy related to whether a non-U.S. bank earned income that was effectively connected with a U.S. trade or business.</li>
<li>Successfully resolved an IRS controversy through a novel use of the “fast track” appeals process, an issue regarding a spinoff and deferred intercompany gain and related debt/equity issues, resulting in a substantial government concession and favorable result on behalf of a U.S. multinational hospitality company.</li>
<li>Successfully resolved at IRS Appeals, with a substantial government concession, an IRS controversy related to certain outbound transfer issues in connection with Section 367 and foreign tax credit issues resulting from Section 304 transactions on behalf of a U.S. multinational manufacturing corporation.</li>
<li>Successfully resolved at IRS Appeals, with a substantial government concession, an IRS controversy related to the sourcing of income and title passage issues on behalf of a U.S. multinational creative arts and manufacturing corporation.</li>
<li>Successfully resolved at IRS Appeals, with a substantial government concession, an IRS controversy related to the sourcing of certain dividend payments to non-U.S. shareholders and related withholding tax considerations on behalf of a U.S.-based entertainment company.</li>
<li>Successfully resolved an IRS controversy in connection with certain bad debt claims and recoveries in foreclosure, as well as other matters, in favor of the taxpayer at the IRS Examination on behalf of a U.S. multinational hospitality company.</li>
<li>Represented a U.S. multinational corporation in connection with an IRS controversy related to claiming a deduction for a foreign currency loss incurred with respect to hedging an acquisition.</li>
<li>Represented a U.S. multinational corporation in connection with an IRS controversy related to the deductibility of certain settlement payments with the SEC associated with international matters.</li>
<li>Represented a foreign corporate taxpayer in connection with whether it was engaged in a U.S. trade or business through a permanent establishment in the United States.</li>
<li>Represented a major multinational technology company in connection with an IRS dispute regarding an international structuring involving intellectual property and cross-border debt obligations.</li>
<li>Counseled a global private equity fund (including supervision of foreign law firms) on transfer pricing controversy issues in India and France, and tax assessments in Australia.</li>
</ul>

Paul M. Schmidt

Paul M. Schmidt

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