Bernie J. Pistillo

Mr. Pistillo is a partner in the San Francisco office of the firm’s Federal Tax Group. He regularly advises on the U.S. federal income tax aspects of international and domestic mergers and acquisitions, corporate restructurings and spin-offs, and tax controversy matters in the international area, particularly transfer pricing, the development and exploitation of technology and intellectual property and the structuring of international operations for both start-up entities and existing corporate groups. His practice involves the coordination of tax laws in multiple jurisdictions to develop and implement cross-jurisdictional tax planning, overall operational synergies and worldwide tax minimization strategies. He also is regularly involved in the negotiation of strategic joint ventures and partnerships and the structuring of private equity funds and their investments. Mr. Pistillo also advises on financial product development and the tax aspects of financial institution and insurance company operations.

Mr. Pistillo is a member of the Dean’s Advisory Board at Tulane University School of Law, the Steering Committee of the Northern California Chapter of the U.S.A. Branch of the International Fiscal Association, the Planning Committee for the USC Gould School of Law Tax Institute, and the Tax Review and the Tax Club, both in New York City. He is admitted to practice in California, New York and Arizona.

He is a frequent lecturer and author on matters relating to international taxation and corporate taxation generally.

Mr. Pistillo is recommended by Legal 500 US for US Taxes: Non-Contentious and International Tax.

Recent Client Transactions include:

• Softbank Corp. in connection with its $1 billion investment in WorldVu Satellites Ltd (OneWeb) and of SoftBank and OneWeb in connection with the negotiation and execution of an agreement pursuant to which OneWeb will merge with Intelsat SA in a share-for-share transaction.
• Temasek Holdings Pte Ltd in making an $800 million investment in Verily Life Sciences (formerly Google Life Sciences), Alphabet’s health-focused subsidiary.
• Boyd Gaming Corporation in the sale of its 50% equity interest, valued at $900 million, in Marina District Development Holding Company, LLC, the parent company of Borgata Hotel Casino & Spa in Atlantic City, New Jersey, to MGM Resorts International.
• The co-founder of Broadcom Corp. in connection with its acquisition by Avago Technologies Ltd. in a cash and stock transaction with a combined enterprise value of $77 billion.
• VMWare in planning a joint venture with EMC Corporation to form a new cloud services business, as well as in connection with the planned $67 billion acquisition of EMC by Dell Inc. using tracking stock of VMWare.
• McKesson Corporation in numerous acquisitions in the healthcare and related areas.
• SoftBank Corp. in connection with its acquisition of a 78% interest in Sprint Nextel for an enterprise value of $44.8 billion.
• MicroPort Scientific Corp. in connection with its acquisition of the worldwide OrthoRecon operating segment of Wright Medical Group Inc.
• Toshiba Tec Corp. on its $874 million acquisition of the worldwide retail store solutions business of IBM Corp.
• Textainer Group Holdings Ltd. in connection with a review of its worldwide operating structure to improve financial and legal efficiencies.
• Novellus Inc. in its tax-free stock-for-stock acquisition by Lam Research Corp valued at $3.3 billion.
• Carlyle Group in its acquisition of Walbro Engine Management from Sun Capital Partners and related LBO financing