William M. Paul

Partner

wpaul@cov.com
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Covington & Burling LLP
1201 Pennsylvania Avenue, NW
Washington, DC 20004-2401
Tel: 202.662.5300


 

Practices

Education

  • University of Michigan Law School, J.D., 1977
    • magna cum laude
    • Michigan Law Review, Note Editor
    • Order of the Coif
  • Johns Hopkins University, B.A., 1973

Judicial Clerkship

  • Hon. Thomas Gibbs Gee, U.S. Court of Appeals, Fifth Circuit, 1977-1978


William Paul is a member of the Tax Group and is resident in the firm's Washington, DC office.  His practice focuses on federal income tax matters, including specialties in the taxation of financial products, financial transactions, and investment funds.  He regularly advises clients on the tax treatment of innovative financial products.  He also represents taxpayers and industry groups before the Treasury Department, the Internal Revenue Service, and Congress.

Mr. Paul is a former Chair of the American Bar Association Tax Section.

Representative Matters

  • Representation of coalition of US options exchanges on legislative and regulatory issues affecting the tax treatment of options.
  • Outside tax counsel to the Investment Company Institute, the national trade association of the mutual fund industry.
  • Advisor to various mutual funds and other investment vehicles on tax issues, including the tax treatment of complex securities.
  • Representation of corporate founder in dispute with IRS regarding tax treatment of variable prepaid forward contracts.
  • Advisor to major multi-national corporations and financial institutions on taxation of financial products in domestic and cross-border contexts.

Previous Experience

  • United States Treasury Department, Office of Tax Policy, Deputy Tax Legislative Counsel (1988-1989)

Honors and Rankings

  • Listed in Best Lawyers in America for more than 10 years
  • Listed in Chambers USA's Guide to America's Leading Business Lawyers (2006-2013)
  • Legal 500 US, Tax (2012-2013) 
  • Washingtonian, Tax "Top Lawyer" (2013)
  • Listed in Who's Who in America, Who's Who in American Law, and The International Who's Who of Business Lawyers
  • Named "The Leading Lawyer in Tax" in Washington, DC by Legal Times (2005)

Memberships and Affiliations

  • American Bar Association Section of Taxation
    • Chair (2011-2012)
    • Vice Chair (Government Relations) (2005-2007)
    • Chair, Tax Shelter Task Force (2002-2005)
  • D.C. Bar Tax Section
    • Chair, Financial Products Committee (2003-2005)
  • American College of Tax Counsel
    • Fellow
  • American Law Institute
    • Member
  • American Tax Policy Institute
    • Member, Board of Trustees

Publications and Speeches

  • "Ability of Treasury Center to Mark to Market Its Nonfunctional Currency Positions, Including Its Own Nonfunctional Currency Debt, Under Section 475," Practising Law Institute (January 2014), Author
  • "New Proposed Regulations Under Section 871(m)," Financial Products Committee, DC Bar Tax Section (12/17/2013)
  • "Tax Treatment of Options," CBOE/OIC Wealth Advisor Forum (10/14/2013)
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