Photo of Anthony D. Pastore

Anthony Pastore is a partner in Mayer Brown’s Chicago office and a member of the Tax Controversy & Transfer Pricing practice.

Since joining the firm in 2013, Anthony has represented corporate, partnership, and individual taxpayers in all stages of tax controversy, including examination, administrative appeal, litigation, and trial. He has experience with transfer pricing allocations, debt-equity characterization, valuations, accounting method changes, substance-over-form arguments, and penalties.

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Scenario

A US company is conducting a global internal investigation. To carry it out, the company plans to transfer documents and emails held by its French subsidiary to the company’s US servers for review and analysis. Aware that Europe has stringent data privacy rules, the US in-house counsel is looking for specific guidance on whether