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David J. Brandon

I simplify complicated transactional tax issues and apply creative and value-driven solutions that let our clients focus on doing interesting and audacious things. Quotation mark
David J. Brandon
David J. Brandon
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About David

David is co-leader of Miller Nash’s international practice team. His practice focuses on domestic and international transactional tax matters, with emphasis on cross-border mergers & acquisitions, reorganizations, spin-offs, investment structures, and joint ventures for middle-market businesses. In this context he aids in identifying appropriate goals, finding creative solutions, and executing strategies for tax-efficiency and limiting risk. This includes, for example, structuring taxable and tax-free transactions, crafting transfer pricing strategies, and, where appropriate, counseling clients with respect to obtaining tax opinions and agency rulings.

For nonprofit and tax-exempt organizations, David provides U.S. tax counsel on matters relating to global operations and maintaining tax-exempt status.

In unraveling complicated transactional tax issues, his clients have described him as “unflappable” and have said they “would need more than 5 stars” to rate his work.

David is the vice-chair of the ABA Tax Section’s Committee on U.S. Activities of Foreigners & Tax Treaties (USAFTT). He is a sought-after speaker and publishes regularly on domestic and international tax issues affecting private and public mergers & acquisitions, reorganizations, and access to capital markets. He teaches International Taxation in the Masters in Accountancy and Masters in Taxation programs at Boise State University, and his clients say that one of his strengths is “translating complicated tax issues to laypeople.”

Representative Experience

  • Domestic & International Tax Planning Plus
    • David has provided U.S. tax counsel to individuals, nonprofits, and companies from around the world and with respect to operations in a variety of countries, including, for example, in the Americas (Brazil, Canada, Chile, Colombia, Costa Rica, Mexico, Nicaragua, and United States), Africa and the Middle East (Ethiopia, Gambia, Ghana, Liberia, Rwanda, Saudi Arabia, Uganda, and United Arab Emirates), Asia (Australia, China, Malaysia, South Korea, and Japan), and Europe (Finland, France, Netherlands, Russia, and Sweden).

    • U.S. tax counsel for Swedish technology, SaaS, and consulting group with respect to intragroup transfer pricing matters and US federal income tax planning.

    • U.S. tax counsel for U.S. distributor with respect to expansion of manufacturing and distribution facilities into Mexico.

    • U.S. tax counsel for U.S. consumer products company with respect to expansion of manufacturing, distribution, and retail facilities in Nicaragua and Costa Rica.

    • U.S. tax counsel for U.S. technology and software development company with respect to operations and expansion throughout Central and South America.

    • Tax counsel for publicly traded bank holding company in acquisition (by tax-free merger) of target company with assets of approximately $3.5 billion.

    • U.S. tax counsel for Seattle-based global consulting and software company in sale to Dutch global consulting firm for approximately $47 million in cash and equity securities.

    • U.S. tax counsel for Canadian automotive sales and services company in acquisition of substantially all the assets of Washington-based dealerships with over $70 million of assets.

    • Tax counsel for publicly traded bank holding company in acquisition (by tax-free merger) of target company with assets of approximately $675 million.

    • U.S. tax counsel for domestic energy storage solutions company in internal restructuring and subsequent sale of over $107 million of equity securities to private equity investors.

    • Tax counsel for publicly traded bank holding company in acquisition (by tax-free merger) of target company with assets of approximately $840 million.

Client Collaborations

Services

Education

  • Advanced Professional Certificate in Transfer Pricing (APCTP), International Bureau of Fiscal Documentation, 2023
  • LL.M., University of Washington School of Law, taxation, 2012
  • J.D., University of Washington School of Law, 2012
  • B.B.A., Gonzaga University, magna cum laude, economics, 2008
    • Beta Gamma Sigma International Honor Society

Bar Admissions

  • Idaho, 2022
  • Oregon, 2014
  • Washington, 2012

Military

  • United States Navy

Additional Information

(SITE) COVID 19 Contributor

Activities

Professional Plus
  • American Bar Association, Member
    • International Law Section
      • International Tax Committee, Steering Group Member
    • Taxation Section
      • U.S. Activities of Foreign Taxpayers and Tax Treaties Committee, Vice Chair, 2023-present
      • Transfer Pricing Committee, Member
  • Idaho Chamber of Commerce, Member
  • Idaho State Bar, Member
    • Taxation, Probate & Trust Section
  • International Fiscal Association, USA Branch, Member
  • Oregon State Bar, Member
    • Taxation Section
      • Executive Committee, 2020-present
      • Laws Committee, 2015-2020
  • Washington State Bar Association, Member
    • Tax Section
Civic Plus
  • Boise State University, Adjunct Professor (International Tax), Summer 2023
  • Kinect Capital, Business Mentor, 2022-present
  • Boise Entrepreneur Week, Planning Volunteer and Speaker, 2022
  • University of Idaho College of Law, Entrepreneurship Law Clinic, Guest Lecturer, 2022
  • Lewis & Clark Law School, Small Business Legal Clinic, Pro Bono Attorney
  • Serendipity Center Inc., Past Board Member
  • University of Washington School of Law, Entrepreneurial Law Clinic, Guest Lecturer, 2014

Recognition

  • Named to Idaho Business Review’s Accomplished Under 40 list, 2023
  • Selected for inclusion in The Best Lawyers in America® (Portland, OR)
    • Tax Law, 2024-present
  • Selected for inclusion in Best Lawyers: Ones to Watch® (Portland, OR)
    • Tax Law, 2021-2023
  • Awarded “Mentor of the Year” by the New Tax Lawyers Committee of the Oregon State Bar Tax Section, 2018
  • Recognized as "Attorney of the Year" by Lewis and Clark's Small Business Legal Clinic, 2017
  • Selected for inclusion as an Oregon Super Lawyer—Rising Stars, 2017-present

Insights from David

David is a regular contributor to Today in Tax, Miller Nash's ongoing series of articles analyzing updates and publications from the IRS.

  • “Financing Prep 101,” Boise Entrepreneur Week, panelist (Oct. 2022)
  • “Digital Assets and Blockchain in M&A: Due Diligence, Key Provisions, Structuring Issues,” Strafford Publications, CLE webinar (July 2022)
    • “Tax Issues,” Multnomah Bar Association, Young Lawyers Section CLE Seminar (Nov. 2020)
    • “International Tax Update,” Oregon State Bar Taxation Section, Portland Lunch CLE series (Jan. 2020)
    • “Oregon Legislative Update,” Oregon State Bar, Taxation Section CLE (Oct. 2019)
    • “Federal, State, and Local Tax Update,” Oregon State Bar, Broadbrush Taxation: Tax Law for Non-Tax Lawyers seminar (Oct. 2019)
    • “Lobbying & Political Activity—What You Need to Know,” Oregon Society of Certified Public Accountants, 2019 Not-For-Profit Conference (Apr. 2019)
    • “Drafting Better LLC Operating Agreements,” Lewis & Clark Law School (Nov. 2017)
    • “Planning a Spin-Off or Just Chasing Your Tail? Planning a Tax-free Spin-Off Under Section 355,” Eugene-Springfield Tax Association (Oct. 2017)
    • “Planning Your Next Event to be Successful and Compliant,” Oregon Society of Certified Public Accountants (OSCPA), What Matters for Not-for-Profits Series (Sept. 2017)
    • “What to Expect When You’re Exempting: A Guide to Property Tax Exemption for Charitable Organizations in Oregon,” Nonprofit Association of Oregon (Mar. 2016)
    • “Crossing the Columbia: An Introduction to Navigating State Taxes in the Pacific Northwest,” Oregon State Bar, Broadbrush Taxation CLE (Oct. 2015)
    Collaborations

    Outside the Office

    David enjoys fly-fishing, Gonzaga basketball, bird-watching, and playing with his five imaginative children.

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