Tax Advisers - Deloitte

United States
Giovanna T Sparagna
Sutherland Asbill & Brennan LLP
1275 Pennsylvania Avenue, NW
Washington, DC 20004
US
Tel: (1) 202 383 0183
Fax: (1) 202 637 3593
Email: giovanna.sparagna@sablaw.com
Website: www.sablaw.com
Giovanna Sparagna is a partner in the tax group at Sutherland Asbill & Brennan, and
focuses her practice on international financing structures, cross-border mergers and
acquisitions and international tax controversies (including transfer pricing).
Before joining the firm, Ms Sparagna served in the office of the chief counsel to the
Internal Revenue Service where she issued opinions for the government on domestic and
international mergers, acquisitions and dispositions.
In private practice, Ms Sparagna advises multinational corporations on cross-border
transactions including planning and controversy matters involving international financing
structures, mergers and acquisitions, and Subpart F issues.
As a consequence of her large multinational practice, Ms Sparagna also handles transferpricing
issues for Fortune 500 companies and foreign-owned clients, working closely with
economic experts in tax planning (for example, establishing cost sharing and related party
licensing arrangements), assessing multi-jurisdictional transfer-pricing exposure,
complying with documentation requirements, and developing audit, litigation, advancepricing
agreement and competent authority strategies. She has been recognized in the
International Tax Review Expert Guides, including The Guide to World’s Leading Tax
Advisers and the World Tax Guide, and in Euromoney Institutional Investor’s World’s
Leading Transfer Pricing Advisers.
Ms Sparagna regularly publishes on wide variety of international subjects. Her recent
publications include:
• “The Administration’s Corporate Tax Shelter Proposals: What are the Limits of
Appropriate Tax Planning?” 40 Tax Management International Journal (special edition,
March 29 1999, S-99);
• “Further IRS Guidance on the Treatment of Section 304 Related Party Sales in the
International Setting” 20 Tax Management International Journal 353;
• “Allocating Foreign Stock Attributes Through Partnerships Under Subpart F –
Planners Beware” Taxation of Global Transactions (Fall 2002);
• “CCA Recasts Sale of Partnership Assets to Trigger Subpart F” CCH Taxation of Global
Transactions (Summer 2003);
• “IRS Closes Technical Loophole to Eliminate Foreign Tax Credit Planning with
Stapled Stock” CCH Taxation of Global Transactions (Winter 2004); and
• “Related Party Stock Sales: Recasting Out of Code Sec 304 Under Rev Rul 2004-83”
CCH Taxation of Global Transactions (Fall 2005).
Ms Sparagna is the chair of ABA FAUST, a member of the executive council for the
Lawyers’ Committee for Shakespeare Theatre and co-chair of the GW/IRS Annual
Institute for International Taxation. She is a frequent speaker for the Georgetown
University American Bar Association International Fiscal Association, Tax Executive
Institute, Structured Finance Institute and National Foreign Trade Counsel.
Ms Sparagna is an adjunct professor of law at the Georgetown University (LLM tax
programme) and frequently lectures on international strategies at conferences hosted by
groups such as the America Bar Association, the International Fiscal Association, the Tax
Executives Institute, the Structured Finance Institute and the National Foreign Trade
Council.
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