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Michael Liu

Principal, International Tax, KPMG US

Santa Clara, CA
Image of Michael Liu

Michael Liu

Principal, International Tax

Michael Liu,  a principal in the International Tax practice of the KPMG Silicon Valley office, specializes in domestic and cross-border transactions involving complex international tax issues, with a focus on intellectual property (IP) and supply chain planning, and related transfer pricing and valuation issues. Prior to joining KPMG, Michael was a tax partner at two international law firms, Baker McKenzie and Morgan Lewis & Bockius.

Michael advises and counsels U.S. and non-U.S. multinational corporations on a range of domestic and cross-border U.S. federal income tax issues, including:

  • Subpart F, global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), base erosion anti-abuse tax (BEAT), and foreign tax credit planning issues
  • Mergers and acquisitions, structured financings, and divestiture planning
  • Repatriation and expatriation planning (predominantly prior to the enactment of the Tax Cuts & Jobs Act (TCJA))
  • Tax disputes and controversies with a particular focus on transactions and arrangements involving the transfer and deployment of IP and related transfer pricing and valuation issues. 

Michael is co-author of Chapter 15 – Foreign Corporations and Foreign Source Income of Federal Income Taxation of Corporations and Shareholders (Bittker & Eustice, 7th Ed.). He is a board member of the Asian Law Alliance (Silicon Valley).

Michael has a BS degree in microbiology and molecular genetics and a BA degree in philosophy from University of California Los Angeles, a JD degree from University of San Diego School of Law, and an LLM degree in taxation from New York University School of Law.

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