William M. Paul


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Covington & Burling LLP
One CityCenter
850 Tenth Street, NW
Washington, DC 20001-4956
Tel: +1 202 662 5300




  • 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 funds, major multi-national corporations and financial services firms 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

  • Chambers USA's Guide to America's Leading Business Lawyers
  • Legal 500 US, "Leading Lawyer" - Tax/Financial Products
  • Best Lawyers in America, Who's Who in America, The International Who's Who of Business Lawyers and other ranking services
  • 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

  • "The Final Section 871(m) Regulations -- Beyond the Basics," Financial Products Committee, DC Bar Tax Section (11/19/2015)
  • "U.S. Tax Developments," ICI Tax & Accounting Conference (9/28/2015)
  • "Current Tax Developments," 2015 Mutual Funds and Investment Management Conference (3/16/2015)
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