Linda Pfatteicher is managing partner of the San Francisco and Palo Alto offices and is a partner in the Tax Strategy & Benefits Group. She focuses her practice on international tax and operational structuring for corporations, including global expansion, global transfer pricing strategy, intangible property planning, cross-border mergers and acquisitions, post-acquisition integration and international tax controversies. Linda has also been instrumental in developing the firm’s autonomous driving initiative and regularly advises companies on the regulatory issues impacting this space.
Linda’s clients range from start-ups to billion-dollar multinationals. She has assisted clients in a wide variety of industries, including, most significantly, technology, medical devices, entertainment software, manufacturing and distribution, oil and gas, consumer products and venture funds.
Linda has worked with her clients in structuring acquisitions, integrating legal entities, working to optimize the foreign/US tax base (including negotiating and obtaining tax holidays and utilizing low-tax jurisdictions), advising on cross-border financing, managing indirect tax costs and ensuring that the final international structure can efficiently meet both US and non-US compliance requirements. She has advised on large-scale international merger and acquisition transactions, as well as tax controversy matters. This work includes disputes related to buy-in and cost sharing agreements and analysis of the impact of corollary effects, such as earnings and profits and foreign tax credits.
Linda also regularly assists clients with developing tax issues, such as the OECD tax framework and EU tax policy strategy, and with issues that may arise under developing tax regimes, such as those of Brazil, Russia, India and China. She has negotiated tax rulings for her clients in the Netherlands, Singapore and Switzerland.
Linda has been active in developing and leading the firm’s autonomous driving initiative, which is focused on addressing a wide range of issues – from regulatory and ethical concerns to cybersecurity and product liability issues. She has advised a variety of companies in the autonomous driving space, including those in the automotive, technology, and insurance sectors.
Linda has previously worked for one of the Big Four accountancy firms, as well as another top 20 international law firm.