Member Profile

Michael Hardgrove is a Partner at DLA Piper and located in the Boston office. His practice focuses on international tax. He has provided international consulting, structuring and intangible transaction services to numerous public and private companies with operations throughout the world. Michael serves his clients as international tax counsel, addressing their cross-border objectives for IP transfers, supply chain conversion, acquisition planning, repatriation and transfer pricing.

He has been repeatedly recognized for his ability to integrate complex tax issues and operational constraints by Chambers USA and The Legal 500 United States.

Here is an overview of the areas that Michael’s practice covers:

Assessing international sales, distribution and manufacturing operations, and evaluating structures, transaction flow, value-chain and business transition.

Designing a comprehensive and tailored strategy that can align or integrate international business functions such as trading companies, shared services centers, regional headquarters, intangible property migration, procurement/sourcing offices, distribution centers, holding companies, treasury centers and/or principal operating models.

Implementing appropriate global structures or modifications to European / APAC business units that include: entity simplification / restructurings, intercompany transaction conversion, valuations, income tax deferral / efficiency, and acquisition planning (pre and post transaction).

Defending the structure and managing related controversy matters for federal and foreign tax audits, including advanced pricing agreements (transfer pricing rulings), competent authority proceedings (bilateral disputes), and tax rulings.

In particular, Michael Hardgrove concentrates on global alignment and integration (G.A.I.N.) in order to assess international tax and operating exposures and then design a structure for cost efficiency that increases enterprise value, by reducing after-tax cost of capital and lowering the effective tax rate on profits from international business activities.

- Cross-border IP transfers

- Supply-chain conversion

- Acquisition planning

- Repatriation

- Transfer Planning

- Global Alignment and Integration

- New Business Formation

Michael Hardgrove serves both private and public companies in a diversity of industries;

- Life science, Pharmaceuticals, Healthcare

- IT Services, Software as a Service

- Financial Services, Global Services

- Consumer Products, Industrial Products

- Entertainment, Sport

- Franchise

Before joining DLA Piper, Michael was with PricewaterhouseCoopers (PwC) for more than 20 years, working in PwC offices in Brussels, San Jose/San Francisco and Seattle. He has served as PwC’s US leader for global structure alignment and as the national tax leader of the industrial manufacturing industry sector.

Earlier in his career, Michael worked as a controller and auditor for six years.

Presenter at many webinars regarding: International franchise structures, tax opportunities and tax challenges for US multinationals operating in Russia, intangible property footprint, tax and legal issues and alternatives when licensing, International M&A strategy considerations and structuring to enhance enterprise value, the taxation of intangible assets and successful international expansions.

Ohio Society of Certified Public Accountants

California Bar Association

Boston Bar Association

Certified Management Accountant (CMA)

The respected English research firm Chambers & Partners has repeatedly recognized Michael in Chambers USA for his work "improving tax efficiency for multinational companies." A client stated, "[h]is knowledge of tax issues affecting hi-tech companies is extensive and his ability to integrate complex tax issues and operational constraints is excellent." Further, the Boston tax practice, led by Michael, "enjoys a robust reputation for its work in corporate restructuring, both domestically and internationally." As one client noted, the Boston tax practice has "excellent technical expertise in corporate re-organizations, with direct, hands-on experience."

Another well-regarded legal directory, The Legal 500 United States, has recommended Michael for his "deep international tax knowledge" and "excellent communication skills."

In addition, DLA Piper's Boston-based tax practice was recognized as the International Tax Law Firm of the Year in Massachusetts by Corporate INTL Magazine in 2014 and 2015.