Gary D. Sprague, a 35-year veteran of international tax law and a partner in Baker McKenzie’s Palo Alto office, focuses his practice on international corporate tax planning and advice, tax controversies and tax issues affecting software and digital enterprises. He was one of five business representatives selected by the OECD to participate in the OECD Technical Advisory Group (TAG) concerning the characterization of electronic commerce revenue for tax treaty purposes, and was elected chair of the business representatives on the TAG. Gary was also appointed by the OECD to serve as the business co-chair of the TAG concerning Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits. He was the Co-General Reporter for the subject Taxation of Income Derived from Electronic Commerce for the International Fiscal Association 2001 Congress. He is a co-author of BNA Tax Management Portfolio No. 555, Federal Taxation of Software and E-Commerce, and is a regular contributor to the Tax Management International Journal’s Leading Practitioner Commentary. He will be the General Reporter for the Main Subject "Big Data and Taxation" of the 2021 IFA Berlin Congress.
Gary focuses his practice on international corporate tax planning and advice, tax controversies and tax issues affecting software, high technology and digital enterprise companies.
Professional Associations and Memberships
- American Bar Association - Section on Taxation
- State Bar of California
- International Fiscal Association - USA Branch
- California~United States (1981)
- Harvard Law School (J.D. cum laude) (1981)
- Stanford University (B.A. Honors) (1977)
- Trinity College, Dublin
- San Francisco
- Author, "Proposed Regulations Rationalize Source of Income Rules for Digital Deliveries of Software and Content," Tax Management International Journal, Bloomberg Tax, 2019
- Author, " If Metternich and Talleyrand Had Talked Tax," Tax Management International Journal, Bloomberg Tax, 2019
- Author, " A Critical Look at the European Commission Staff Impact Assessment Relating to the Proposed EU Directives on Taxation of the Digital Economy," Tax Management International Journal, Bloomberg Tax, 2019
- Co-author, "The Tax Cuts and Jobs Act: Congress Passes A Major Tax Bill For First Time in Thirty Years," Baker McKenzie December 2017
- Author, "The Broader Consequence of the EU Debate on Taxing the Digital Economy," Tax Management International Journal, Bloomberg Tax, 2017
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