A Sutherland partner for nearly 20 years, Giovanna Sparagna counsels multinational corporations on international tax planning and cross-border controversy matters that range from financing, royalty structures, international mergers and acquisitions and international lending transactions, to contract manufacturing structures, cross-border service and supply agreements, and repatriation planning. As part of her extensive multinational practice, Giovanna also handles transfer pricing matters for Fortune 50 companies and foreign-owned clients, working closely with economic experts in tax planning to establish cost sharing and related party licensing arrangements; assess multijurisdictional transfer pricing exposure; comply with FIN 48 and return documentation requirements; and develop audit, litigation, advance pricing agreement and authority strategies.
Continuing to serve as Of Counsel in Sutherland’s Tax Practice Group since retiring in 2012, Giovanna also handles controversy matters that include: government challenges to cross-border financing transactions involving arbitrage elements, such as deferred share agreements and repo transactions; foreign tax credits under non-compulsory and economic substance theories; offshore intangible structures; treaty exemptions on complex, multiparty financing transactions; and validity of international restructuring. Prior to joining Sutherland, Giovanna served in the Office of the Chief Counsel at the Internal Revenue Service (IRS), delivering rulings and legal advice on domestic and international mergers, acquisitions, and dispositions. Additionally, she is a former adjunct professor of law at Georgetown University Law Center.
Awards and Rankings
Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax (2010-2014)
Recognized in The Guide to World’s Leading Tax Advisers (each edition since 2002)
Fellow, American College of Tax Counsel (2013)
Advisory Board Member and Former Private Sector Chair, GW/IRS Annual Institute for International Taxation
Council, International Fiscal Association (U.S.A. Branch)
Former Chair, Committee on Foreign Activities of U.S. Taxpayers, Section of Taxation, American Bar Association