Patricia Gimbel Lewis is a member in Caplin & Drysdale's Washington, D.C. office, having started with the firm in 1971. Services Ms. Lewis' practice currently focuses on international transfer pricing issues, competent authority matters, and other aspects of international taxation. This includes tax planning advice on compliance with U.S. and foreign transfer pricing rules in connection with ongoing business operations or business transactions, as well as assistance in the event of tax audits and other administrative controversies. A particular emphasis is the negotiation of advance pricing agreements (APAs) between taxpayers, the IRS, and foreign tax authorities. Highlights Ms. Lewis has represented U.S. subsidiaries of major Japanese corporations, as well as affiliates of corporations in the United Kingdom, Sweden, Germany, and other foreign countries. She was particularly active in the fight to protect the confidentiality of APAs from unwarranted disclosure. Professional Activities · Member, D.C. Bar Taxation Section; Co-Chair, Steering Committee, 1992-1995 · Member, IRS Commissioner's Advisory Group, 1994 -1996 · Speaker at conferences for the following groups, among others: ABA Taxation Section, IRS, Tax Executives Institute, IRS/GWU International Tax Institute, World Trade Institute, and International Fiscal Association Awards & Honors · Ranked as a leading lawyer in International Tax in the 2011 edition of The Legal 500, and in Tax Controversy in the guide's 2010 edition · Ranked as a Top Lawyer in the 2008-2011 editions of Chambers USA: 2011 - Band 3 in Tax - District of Columbia · Selected in Legal Media Group's Guide to the World's Leading Lawyers - Best of the Best USA 2009 and 2011, as well as in their Guide to the World's Leading Tax Advisers, Transfer Pricing Advisers, and Women in Business · Recommended by PLC Which Lawyer? in international tax and AV rated by Martindale-Hubbell · Listed in The Best Lawyers in America in the specialties of Employee Benefits Law and Tax Law from 2003-2012; ranked as a "Super Lawyer" and one of the "Top 50 Women in Washington, DC" by DC's Super Lawyers magazine from 2007-2011 Recent Publications · Short Cuts for Small Fry: Why the IRS Should Reconsider Transfer Pricing Safe Harbors for Small Taxpayers, Transactions, Tax Management Transfer Pricing Report (BNA) (April 2011) · Survival Techniques: Transfer Pricing in a Sick Economy, THE TAX EXECUTIVE (May-June 2009) · Coming Full Circle? Secondary Adjustments and Repatriation in Transfer Pricing Cases, Tax Management Transfer Pricing Report (BNA) (May 8, 2008) · Play it Again Sam - The IRS (More or Less) Finishes the Section 482 Services Regulations, THE TAX EXECUTIVE (September/October 2006) · The Law of Unintended Consequences: International Implications of Section 409A, THE TAX EXECUTIVE (March/April 2005) · The Final Word on Stock Options in Cost Sharing Arrangements??, TAX MANAGEMENT INTERNATIONAL JOURNAL (December 2003) · Second First? Transfer Pricing in Secondment of Personnel, THE TAX EXECUTIVE (July/August 2002) Other Professional Affiliations American Bar Association (Section of Taxation, Transfer Pricing Committee and other international committees) Fellow, American Bar Foundation Fellow, American College of Tax Counsel Charter Fellow, American College of Employee Benefits Counsel IRS/George Washington University International Tax Institute on International Taxation, Co-Chair, 2000-01; Member of Advisory Board, 1995-Present The District of Columbia Bar (Taxation Section) |