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Bernadette Accili
Partner, Tax Department bernadetteaccili@paulhastings.com Bernadette Accili is a partner in the Tax practice of Paul Hastings and is based in the firms Milan office. As chair of the Tax practice in Milan, Ms. Accili represents clients in structured and asset finance deals, and investment funds transactions, particularly in the energy and real estate market. She works to identify the most appropriate tax solutions for clients in cross-border transactions, operating in close co-operation with local counsel worldwide. Ms. Accili is also active in corporate restructurings in the insolvency area as well as in corporate mergers and reorganizations. She also represents clients in complex tax disputes, both leading to settlement, or to ground breaking litigation before national Courts as well as the EC Court of Justice.

Milan
T: 39-02-30414-208 F: 39-02-30414-005

Practice Areas
Europe Tax Litigation and Controversy Tax Advisory

Admissions
Italy New York Bar

Recent Representations Lehman Commercial Paper, Inc. (Debtor-in-Possession) in the Italian law aspects of the restructuring of an existing English law loan secured over units of an Italian law fund. The matter is handled by the London office in conjunction with the Milan practice for the tax aspects of the transaction. Exor S.p.A. on the proposed sale of one of its portfolio companies, Alpitour, the leading Italian and one of the major European tour operators with subsidiaries in various countries in Europe and outside of Europe. The transaction, one of the most significant M&A deals announced in 2011 in Italy, is conducted through an auction process with a number of international bidders. In particular, we assist the clients on tax matters. IBM Italia S.p.A. and providing assistance to the client with respect to the compliance of the by-laws of the health care fund for managers of IBM to the exemption on income tax and VAT rules. Coca-Cola regarding the analysis of the so called junk food tax and possible remedies in 7 EU countries. Strategic Value Partners in the 1.2 billion restructuring of the Ferretti Group, a

Languages
French

Education
Georgetown University Law Center, LL.M., 1996 University of Rome School of Law, J.D., 1991

Atlanta, Beijing, Brussels, Chicago, Frankfurt, Hong Kong, Houston, London Los Angeles, Milan, New York, Orange County, Palo Alto, Paris San Diego, San Francisco, Seoul, Shanghai, Tokyo, Washington DC

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world leader of luxury yachts, which entails an equity investment in a jointventure with Chinese group Weichai and RBS. A leading Italian telecommunication company and its subsidiaries and providing assistance with regards to tax litigation before the Court of Cassation. In particular, assisting one of its subsidiaries in a tax litigation on deductibility of costs borne in tax haven jurisdictions. Accolades and Recognitions Listed in the 2012 edition of The Legal 500 Bernadette Accili is considered as responsive and proposes solutions Mentioned in the 2010 edition of Expert Guides by Legal Media Group Tax Advisors Listed in the 2010 edition of The Tax Directors Handbook Speaking Engagements and Publications Diritto e Pratica Tributaria internazionale, Italy: "The Criminal liability of Company Directors of Shell Companies" DPTI, II, 164, 2012 Chair IBA conference 2012 in the Tax leverage: the tax treatment of debt in the wake of the global financial crisis panel Dublin, October 1, 2012 Speaker, IBA conference 2011 in the Taxation of Athletes and Entertainers in Dubai, November 1, 2011 European taxation, United Kingdom: VAT and appealability of the Tax Authoritys decision in light of the new Italian tax settlement provision. European taxation, 2009, p. 78 Lecturer at the University of Bocconi, November 4 2009 Speaker in the anti-avoidance panel at the ITWP conference in London, March 3, 2008 Speaker in the treaty shopping panel at the ABA, IBA, IFA conference on Tax Planning Strategies U.S and Europe Frankfurt, April 19, 2007 Italian speaker, IBA conference 2006 in the Cross Border Loss Recognition panel held in Chicago, September 20 2006 Speaker, Opening conference of the IFA Magreb Branch, Marrakech, May 1314, 2006 Co-chair in the Reorganizations and Restructuring panel at the ABA, IBA, IFA conference on Tax Planning Strategies U.S and Europe, Rome, March 30, 2006 Italian speaker at the IBA conference 2004 in the Tax Reps and Warranties panel held in Auckland, September 28 2006 Diritto e Pratica Tributaria, Italy: The Philip Morris case. DPT 2004, I, p. 65 Il Sole 24Ore, Italy: The European Court of Justice declares unlawful domestic

Atlanta, Beijing, Brussels, Chicago, Frankfurt, Hong Kong, Houston, London Los Angeles, Milan, New York, Orange County, Palo Alto, Paris San Diego, San Francisco, Seoul, Shanghai, Tokyo, Washington DC

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exemptions on dividends. Il Sole 24Ore July 5, 2000 Rivista di diritto tributario, Italy: The Shumacker case and the nondiscrimination principle in the Treaty of Rome. Dir. Trib. 1995, vol XI, p. 439 Professional and Community Involvement Treasurer of the tax committee of the International Bar Association (IBA) Admitted at the Corte di Cassazione, 2007 Admitted at the US Supreme Court, 2006 Member of the New York Bar, New York USA, 1997 Member, Italian Bar Association, Milan Italy, 1994 Education Georgetown University Law Center, Washington DC USA, LL.M. in Common Law Studies, 1996, Fulbright scholarship Master paper: "The US Regulations and the OECD Guidelines on Transfer Pricing" College of Europe, Bruges Belgium, LL.M. in European Community Law, 1993, Ministry of Foreign Affairs Italy Scholarship Master paper: "Crossborder mergers in the community fiscal system and their impact on national legislation" .

News
July 06, 2012 Paul Hastings Advises Strategic Value Partners on Ferretti Group Restructure April 20, 2012 Paul Hastings Represents Exor in the Sale of Alpitour July 21, 2009 Paul Hastings represents Intesa Sanpaolo on 5.9 billion securitisation

Publications
July 17, 2013 Le Nuovissime Disposizioni Regolamentari Comunitarie e Italiane Tra Corporate Governance e Gestione Del Rischio Fiscale

Atlanta, Beijing, Brussels, Chicago, Frankfurt, Hong Kong, Houston, London Los Angeles, Milan, New York, Orange County, Palo Alto, Paris San Diego, San Francisco, Seoul, Shanghai, Tokyo, Washington DC

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June 03, 2013

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New Italian Rules for Joint and Several Liability in Contracts and Subcontracts

February 25, 2013 New Tax Rules for Bonds Issued by Italian Non-Listed Corporations - A Foreign Investor's View

February 04, 2013 Italy: The Recently Introduced FTT What's New and What are the Implications for FTT Taxpayers?

October 26, 2012 New Italian Measures Facilitate Debt Restructuring and Protect DIP Financing

March 15, 2012 Tax Avoidance: Criminal Liability for a Foreign Companys Management

November 24, 2009 The Reimbursement of Withholding Tax on Dividends Distribution of NonResident Minority Stakeholders of Italian Companies: an EU Judgment

August 04, 2008 New Provisions to the Taxation of Real Estate Funds in Italy

June 09, 2008 Tax Settlement in Pre-insolvency Procedures in Italy