William S. Garofalo practiced for over 19 years as a litigator and examination advisor for the Internal Revenue Service before joining the New York office of Baker & McKenzie in early 2000.  Mr. Garofalo now advises taxpayers on federal and state tax matters and represents taxpayers in tax controversies and litigation.   In the captive insurance area, he has assisted taxpayers with the creation and maintenance of captive insurers, transfer pricing studies, federal and SALT planning, and tax examinations.  While with the IRS, he was co-counsel for the government in the UPS litigation, a leading Tax Court case dealing with the sham nature and transfer pricing of reinsurance with a related entity, and other large Tax Court cases.   Mr. Garofalo also assisted in IRS examinations dealing with numerous captive issues.  Mr. Garofalo teaches at Seton Hall Law School (corporate taxation), Rutgers University (Tax Procedure) and at the National Institute of Trial Advocacy.  He has an LLM (taxation) from New York University.   Mr. Garofalo speaks often at various seminars and is widely published.  His publications include “Transfer Pricing – Alternative Strategies” (BNA Tax Management Portfolio), and numerous articles on tax controversy or transfer pricing in the Journal of International Taxation, International Tax Review, International Tax Journal, Practical U.S./International Tax Strategies and PLI.