Elizabeth J. Stevens

Elizabeth J. Stevens: Attorney with Caplin & Drysdale, Chartered
  • Associate at Caplin & Drysdale, Chartered (67 Attorneys)
  • One Thomas Circle NW, Suite 1100, Washington, DC 20005
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Elizabeth Stevens is an Associate in Caplin & Drysdale’s Washington, D.C., office. She joined the firm in 2015.


Ms. Stevens' practice centers on international tax planning and advocacy for corporate clients. Matters involve transfer pricing, U.S. inbound investment taxation, and counseling on the tax implications of multinational groups' transactions and entity structures. Illustrations of Ms. Stevens' legal services include:

•advising corporate clients on transfer pricing planning, documentation, and compliance, including negotiating Advance Pricing Agreements;
•counseling clients on the implications of the 2017 U.S. tax reform for particular business lines and models and on alternatives for mitigating resulting risk and uncertainty;
•guiding clients seeking Competent Authority assistance under bilateral income tax treaties and advising on other treaty-related matters, such as the creation and taxation of permanent establishments and eligibility for treaty benefits;
•evaluating and advising on the tax consequences of multinational enterprises’ restructuring proposals;
•representing clients in LBO transactions and assisting with the drafting and negotiation of partnership and LLC operating agreements; and
•representing clients in tax litigation matters and providing strategic guidance in pre-litigation controversies.


Previously, Ms. Stevens served as a judicial clerk to Judge Robert A. Wherry, Jr. (Ret.) of the U.S. Tax Court and practiced at a regional law firm in California, where she assisted corporate and individual clients with business transactions, estate planning, employment matters, and civil litigation. Ms. Stevens has also practiced as a litigation fellow at Americans United for Separation of Church and State in Washington, D.C., where she represented plaintiffs in federal court lawsuits involving free speech and religious discrimination claims. Prior to her fellowship, Ms. Stevens served as a law clerk to then-Chief Judge Royce Lamberth of the U.S. District Court for the District of Columbia.

Ms. Stevens graduated first in her class from California Western School of Law. Before earning her law degree, Ms. Stevens served as a U.S. naval officer. She received her commission through the Navy's ROTC program after earning a degree in international political economy at Georgetown University.

Recent Publications

• INSIGHT: BEAT Strikes the Wrong Note, with Peter A. Barnes, Bloomberg Tax: Daily Tax Report, March 16, 2018
• GILTI Pleasures, with H. David Rosenbloom, Tax Notes International Magazine, February 12, 2018
• New Partnership Audit Rules Go Live, with Jonathan S. Brenner, Caplin & Drysdale Client Alert, January 9, 2018
• Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets, with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Arielle M. Borsos, Caplin & Drysdale Client Alert, November 6, 2017
• Different Viewpoint Not a Misrepresentation: Tax Court Holds IRS Abused Its Discretion in Cancelling Eaton's APAs, with Patricia Gimbel Lewis and J. Clark Armitage, Caplin & Drysdale Client Alert, August 24, 2017
• Congress Looks to Fix New Partnership Audit Rules, with Charles M. Ruchelman, Jonathan S. Brenner, and Rachel L. Partain, International Law Office, January 6, 2017
• Congress Looks to Fix New Partnership Audit Rules, with Charles M. Ruchelman, Jonathan S. Brenner, and Rachel L. Partain, Caplin & Drysdale Client Alert, December 14, 2016
• New Regulations Change Allocation of Partnership Liabilities, with Jonathan S. Brenner, International Law Office, November 4, 2016
• New Regulations Change Allocation of Partnership Liabilities, with Jonathan S. Brenner, Global Tax Weekly, November 3, 2016
• New Regulations Change Allocation of Partnership Liabilities, with Jonathan S. Brenner, Caplin & Drysdale Client Alert, October 24, 2016
• 2016 Federal Tax Benefits for Hiring Qualified Veterans, National Guard Members and Reservists (Book), with Beth Shapiro Kaufman, Caplin & Drysdale, Chartered, March 1, 2016
• Transfer Pricing Audits: Flipping the Tested Party, with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Neal M. Kochman, Wolters Kluwer, August 27, 2015
• Transfer Pricing Audits: Flipping the Tested Party, with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Neal M. Kochman, Caplin & Drysdale Client Alert, August 13, 2015
• IRS Releases Guidelines for Examining CFC Transactions, with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Neal M. Kochman, Caplin & Drysdale Client Alert, July 29, 2015
• OECD's Proposed New Approach to Transfer Pricing of Intangibles: A Critique, New York University, June 29, 2014
• Crawford's Last Stand? What Melendez-Diaz v. Massachusetts Means for the Confrontation Clause and for Criminal Trials, 2 AKRON J. CONST. L. & POL'Y 81, June 2, 2011
• COMMENT: Deputy-Doctors: The Medical Treatment Exception after Davis v. Washington, 43 CAL. W. L. REV. 451, 2007, May 1, 2007

Recent Speaking Engagements

•Moderator, Transfer Pricing and The U.S. Tax Landscape - One Year After Tax Cuts and Jobs Act, TP Minds International 2019, March 19, 2019
•Moderator, Eyes on the Horizon: What Will Follow the TCJA?, Federal Bar Association, 43rd Annual Tax Law Conference, March 8, 2019
•Chair, International Symposium, Federal Bar Association, 43rd Annual Tax Law Conference, March 7, 2019
•Panelist, Alternatives to Resolving Large, Complicated, Corporate Tax Disputes, Leading Women In Tax Forum 2019, February 26, 2019
•Panelist, Recent International Tax Developments Under TCJA - Section 965, GILTI and BEAT, Committee of Banking Institutions on Taxation (CBIT), 49th Annual Fall Tax Day, October 25, 2018
•Speaker, Overview of U.S. Tax Reform, AICPA & CIMA U.S. Tax Reform Conference, September 17, 2018
•Chair, Tax Incentives to Attract Foreign Direct Investments Without Eroding the Tax Base, 2018 International Fiscal Association Congress, September 5, 2018
•Speaker, Part 4 of 4 New Tax Practitioners Lunch Series, D.C. Bar, May 30, 2018
•Panelist, Amending LLC and Partnership Agreements to Address Tax Reform and the New IRS Audit Rules, Strafford Publications, May 16, 2018
•Panelist, A Renewed Focus on CoGS, 2018 ABA Section of Taxation May Meeting, May 10, 2018
•Moderator, Centralized Partnership Audit Regime Update, Part 2, D.C. Bar, April 4, 2018
•Moderator, Impact of the U.S. Tax Reform on Transfer Pricing Planning, TP Minds International, March 20, 2018
•Panelist, To the Shores of Tripoli: A Military Tax Overview, American Bar Association Section of Taxation 2018 Midyear Meeting, February 9, 2018
•Panelist, TP Challenge: Analysis of EU State Aid Decision for Apple, National Association for Business Economics, 7th Annual NABE Transfer Pricing Symposium, July 19, 2017
•Panelist, Competent Authorities - Live Negotiation Simulations Involving Canada, China, and US, University of San Diego School of Law, 5th Annual USD Transfer Pricing Symposium, April 27, 2017
•Panelist, The Foreign Tax Credit, ABA Tax Section, January 20, 2017
•Moderator, Transfer Pricing Litigation Through the Lens of Medtronic, ABA Tax Section, January 19, 2017

Recent News

•Elizabeth Stevens Comments: U.S. Seeks to Broaden Digital Tax Discussions, Law360 Tax Authority, March 8, 2019
•Caplin & Drysdale Honors the Women of the Firm, Caplin & Drysdale, March 8, 2019
•5 Caplin & Drysdale Attorneys Contribute to FBA 2019 Tax Law Conference, Caplin & Drysdale, March 6, 2019
•Law360 Quotes Elizabeth Stevens: Lack of Noncash Exceptions in BEAT Rules Has Wide Scope, Law360, December 18, 2018
•David Rosenbloom and Elizabeth Stevens Submit Amicus Brief to Uphold Decision Favoring Amazon in IRS Transfer Pricing Dispute, Law360, July 9, 2018
•Law 360 Quotes Elizabeth Stevens on BEAT Policies to Look Out For Later This Year, Law360, July 5, 2018
•U.S. News Quotes Elizabeth Stevens on How Changes to BEAT Could Impact Cost of Goods Sold, U.S. News & World Report, May 25, 2018
•9 Caplin & Drysdale Attorneys Contribute to ABA's Annual Section of Taxation Meeting, Caplin & Drysdale, May 9, 2018
•Elizabeth Stevens Discusses Further Clarification on BEAT Rule with Bloomberg, Bloomberg BNA, April 16, 2018
•Law360 Speaks to Elizabeth Stevens About Retiring Tax Court Judge Robert Wherry, Law360, January 5, 2018
•Law360 Talks to Clark Armitage, Peter Barnes, and Elizabeth Stevens on International Tax Cases to Watch in 2018, Law360, January 2, 2018
•Caplin & Drysdale Honors All Who Served in Our Nation's Military, Caplin & Drysdale, November 11, 2016
•Elizabeth Stevens Speaks with Army Wife Talk Radio on Employer Tax Breaks for Hiring Vets, Army Wife Talk Radio, April 5, 2016
•Caplin & Drysdale Creates New Version of Tax Guide to Help Employers Hire Veterans, Caplin & Drysdale, March 7, 2016

Areas of Practice (4)

  • Business
  • International Tax
  • Tax Controversies
  • Investment & Transactional Tax

Education & Credentials

Contact Information:
(202) 862-5039  Phone
University Attended:
Georgetown University,, B.S. in Foreign Service, magna cum laude, 2002
Law School Attended:
New York University School of Law, LL.M. in Taxation, 2014; California Western School of Law, J.D., summa cum laude, 2008
Year of First Admission:
U.S. Tax Court; California; District of Columbia; U.S. Supreme Court

Other Professional Affiliations

Member, U.S. Council for International Business

Vice Chair, American Bar Association, Section of Taxation, Transfer Pricing Committee


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