Patricia Gimbel Lewis

Patricia Gimbel Lewis: Attorney with Caplin & Drysdale, Chartered AV stamp icon
  • Member at Caplin & Drysdale, Chartered (67 Attorneys)
  • One Thomas Circle NW, Suite 1100, Washington, DC 20005
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Patricia Gimbel Lewis is a Member in Caplin & Drysdale's Washington, D.C., office, having started with the firm in 1971.


Ms. Lewis' practice 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.


Ms. Lewis represents businesses in many industries, including financial services. She has worked with major U.S.-based multinationals as well as U.S. affiliates of foreign corporations, involving cross-border transactions with Japan, the United Kingdom, France, India, Canada, Brazil, Sweden and Germany, among others. Ms. Lewis was particularly active in the fight to protect the confidentiality of APAs from unwarranted disclosure.

Awards & Rankings

Chambers USA, 2008-Present
The Legal 500, Leading Lawyer, 2011-2013; Recommended, 2014-Present
The Legal 500, International Tax Team of the Year, 2014-2015
Best Lawyers in America, Women in the Law, International Tax and Employee Benefits, 2016; Listed 2003-Present
Super Lawyers, Top 50 Women, 2008-2012, Washington, D.C. 2008-Present
Fortune Magazine, Women Leaders in the Law, 2014
Expert Guides' The Best of the Best, Transfer Pricing, 2014-Present
Expert Guides' World's Leading Women in Business Law, Transfer Pricing, 2010-Present
Expert Guides' World's Leading Tax Advisers, 2008, 2014-Present
Expert Guides' World's Leading Transfer Pricing Advisers, 2003-Present
The Washingtonian, Top Lawyer, 2017-Present
Lexology, Client Choice, Corporate Tax, Washington, D.C., 2019
Martindale-Hubbell AV Preeminent

Recent Publications

• 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 J. Clark Armitage and Elizabeth J. Stevens, Caplin & Drysdale Client Alert, August 24, 2017
• Where Have All the Transfer Pricing Safe Harbors Gone? A Plea for Reinvigoration, Bloomberg BNA, Tax Management Transfer Pricing Report, February 23, 2017
• Coca-Cola Company Challenges $9 Billion Transfer Pricing Adjustment, with J. Clark Armitage, International Law Office, February 5, 2016
• Is It the Real Thing? The IRS Makes $9+ Billion of Transfer Pricing Adjustments Against The Coca-Cola Company, with J. Clark Armitage, Caplin & Drysdale Client Alert, December 23, 2015
• Response to Final OECD BEPS Tome, with Peter A. Barnes, J. Clark Armitage, and H. David Rosenbloom, International Law Office, October 30, 2015
• The Final OECD BEPS Tome Has Arrived, with H. David Rosenbloom, J. Clark Armitage, Peter A. Barnes, and Neal M. Kochman, Caplin & Drysdale Client Alert, October 8, 2015
• Strategic Resets Under the New MAP and APA Revenue Procedures, with Neal M. Kochman, J. Clark Armitage, and Sae Jin Yoon, Caplin & Drysdale Client Alert, September 23, 2015
• 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
• Treasury Proposes Significant Changes to U.S. Model Tax Treaty, with H. David Rosenbloom, J. Clark Armitage, Peter A. Barnes, and Neal M. Kochman, Caplin & Drysdale Client Alert, May 26, 2015
• OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns, with Peter A. Barnes, J. Clark Armitage, and Neal M. Kochman, Global Tax Weekly, November 6, 2014
• Remain Vigilant On Indian Permanent Establishments, Even After the Favorable e-Funds Decision, with Peter A. Barnes and J. Clark Armitage, Global Tax Weekly, July 10, 2014
• The New APMA Procedures - Cosmetic or Cosmic?, Tax Management International Journal, March 14, 2014
• Bold Shift in IRS Approach to Transfer Pricing Controversies, with J. Clark Armitage, Peter A. Barnes, and Neal M. Kochman, Caplin & Drysdale Client Alert, February 27, 2014
• Cruising Toward Safe Harbors for Transfer Pricing?, with Stafford Smiley, Corporate Taxation, March 1, 2013
• Safe at Last? Transfer Pricing Safe Harbors on the Horizon, Bloomberg BNA, September 6, 2012
• What You Really Need to Know About Transfer Pricing, The Metropolitan Corporate Counsel, Inc., July 1, 2012
• Short Cuts for Small Fry: Why the IRS Should Reconsider, BNA Tax Management-Transfer Pricing Report, April 21, 2011
• Certainty for Reporting Uncertain Tax Positions (UTP) to IRS, with Christopher S. Rizek, Caplin & Drysdale Client Alert, October 13, 2010
• More and More Transfer Pricing Enforcement in Store!, with Neal M. Kochman and H. David Rosenbloom, Caplin & Drysdale Client Alert, August 6, 2010
• IRS Launches New Transfer Pricing Practice -- Pilot Program Will Select Audit Cases for Scrutiny, with Neal M. Kochman and H. David Rosenbloom, Caplin & Drysdale Client Alert, May 5, 2010
• Looking for FBARs in All the Wrong Places? Limited Relief in New Interim Guidance, with Scott D. Michel, Caplin & Drysdale Client Alert, March 15, 2010
• Survival Techniques: Transfer Pricing in a Sick Economy, The Tax Executive, May 1, 2009
• Last-Minute Changes and Partial Delays Under New Intercompany Service Rules, Caplin & Drysdale, February 1, 2007
• Pay Immediate Attention to Far-Reaching Regulations on Intercompany Services, Caplin & Drysdale, October 1, 2006
• News on the Transfer Pricing Front, Caplin & Drysdale, July 1, 2004
• Markers and Musings: The Proposed Section 482 Service Regulations, The Tax Executive, December 1, 2003
• Transfer Pricing: New Rules for Services and Intangibles, Caplin & Drysdale, November 1, 2003
• Transfer Pricing: IRS Cracking Down on Transfer Pricing Compliance, Caplin & Drysdale, April 1, 2003
• Option Wars: Upping the Ante for Cost Sharing Arrangements, with Neal M. Kochman, Tax Management International Journal, November 8, 2002
• Second First Transfer Pricing Issues In Secondment of Personnel, The Tax Executive, September 1, 2002
• Cost-Sharing Arrangements Come of Age, with Neal M. Kochman, Tax Management Memorandum, August 28, 2000
• Mining For Nuggets in the IRS APA Report, The Tax Executive, May 1, 2000
• Transfer Pricing Thoughts - North America: More Thoughts On APA Disclosure, Global Transfer Pricing, March 1, 2000
• A New Way to Resolve a Factual Issue with the IRS Before Filing a Return, with Christopher S. Rizek, Caplin & Drysdale, February 21, 2000
• Transfer Pricing Thoughts - North America: Thoughts on Code Sec. 482 and Rising Standards of Proof, Global Transfer Pricing, December 1, 1999
• Transfer Pricing Thoughts - North America: Thoughts on Control, Global Transfer Pricing, October 1, 1999
• Transfer Pricing Thoughts - North America: Thoughts on Cooperatives, Global Transfer Pricing, August 1, 1999
• Transfer Pricing Thoughts - North America: Thoughts on APA Disclosure, Global Transfer Pricing, June 1, 1999
• Transfer Pricing Thoughts - North America: The Euro and the Situs of the Borrower Rule, Global Transfer Pricing, April 1, 1999
• Transfer Pricing Thoughts - North America: Thoughts on Joint Ventures, Global Transfer Pricing, February 1, 1999

Recent Speaking Engagements

Ms. Lewis regularly speaks before large groups on topics relating to international tax and transfer pricing. Groups include the ABA Taxation Section, IRS, Tax Executives Institute, IRS/GWU International Tax Institute, and International Fiscal Association. Below is a list of Ms. Lewis' recent speaking engagements.

•Panelist, (1) Recent Developments of Transfer Pricing Regimes and Practices and (2) How to Cope with Global Transfer Pricing Challenges, Yulchon LLC / Korea International Trade Association (KITA), November 2, 2017
•Panelist, Recent U.S. Transfer Pricing Litigation and What It Means, National Association for Business Economics, 7th Annual NABE Transfer Pricing Symposium, July 19, 2017
•Panelist, ABA-APMA Roundtable, 2017 ABA Section of Taxation May Meeting, May 13, 2017
•Moderator, The Great TP Debate, National Association for Business Economics, 6th Annual NABE Transfer Pricing Symposium, July 19, 2016
•Panelist, BEPS Core Concepts and Themes, Bloomberg BNA, Global Transfer Pricing Conference - Washington, D.C., June 12, 2015
•Transfer Pricing Update: Discussion of Recent Issues and Guidance on Transfer Pricing, American Petroleum Institute, 81st Annual Federal Tax Forum, April 28, 2015
•Moderator, Treaties: BEPS-Driven Conceptual Changes and Dispute Resolution Needs, USA Branch of the International Fiscal Association, 2015 Annual Conference, February 26, 2015
•Moderator, Advance Pricing Agreement and Competent Authority Update, American Bar Association, 2014 Joint Fall CLE Meeting, September 19, 2014
•Speaker, Risks in a TP Context: What are They, What Does it Mean to Move Them? Expected Returns?, 4th Annual Transfer Pricing Symposium, National Association for Business Economics (NABE), July 23, 2014
•Moderator, Using APAs and MAP to Mitigate Risk and Disputes, TP Minds Americas Transfer Pricing Summit 2014, February 18, 2014
•Chair, The New APMA Revenue Procedures, District of Columbia Bar Association, February 12, 2014
•Speaker, Transfer Pricing, The George Washington University Law School 27th Annual Institute on Current Tax Issues in International Taxation, December 12, 2013
•Chair, A Practical Guide to Transfer Pricing: International Developments and the U.S. Response, Federal Bar Association, 37th Annual Tax Law Conference, March 1, 2013
•Chair, Safe Harbor Challenge, National Association for Business Economics (NABE), July 31, 2012
•Speaker, Roundtable Discussion with IRS National Director of Transfer Pricing Operations, International Fiscal Association (IFA), July 25, 2012
•Panelist, OECD's Work on Transfer Pricing and Administration, OECD International Tax Conference, June 4, 2012
•Chair, Striving for Efficiencies in Transfer Pricing Enforcement and Compliance, The George Washington University Law School, 24th Annual Institute on Current Issues in International Taxation, December 15, 2011
•Speaker, APAs - An Alternative to the Traditional Examination Process, Pharmaceutical & Medical Device Tax Management & Transfer Pricing Conference, June 21, 2010
•Speaker, Korea-U.S. Advance Pricing Agreements: A Time-Tested Approach, for New or Uncertain Times, Yulchon LLC, October 15, 2009

Recent News

•Caplin & Drysdale Honors the Women of the Firm, Caplin & Drysdale, March 8, 2019
•Lexology's Client Choice Recognizes Patricia Lewis for Corporate Tax Legal Services, Lexology's Client Choice , February 7, 2019
•Patricia Lewis Talks to Law360: Tariffs Could Throw Advance Pricing Agreements Into Doubt, Law360, November 19, 2018
•Law360 Quotes Patricia Lewis on IRS Revamp of APA Program, Law360, September 25, 2018
•Bloomberg BNA Quotes Patricia Lewis: 4 Things to Know About the IRS's Intercompany Pricing Deals, Bloomberg BNA, August 27, 2018
•Law360 Quotes Patricia Lewis: IRS 'Reference Set' Library Could Speed Up Transfer Pricing Cases, Law360, June 18, 2018
•2018 Legal 500 Distinguishes 18 Caplin & Drysdale Attorneys, Firm Renews Top-Tier Firm Ranking for Tax Controversy, The Legal 500, May 31, 2018
Chambers USA Recognizes 10 Caplin & Drysdale Lawyers as Leaders in Their Fields , Chambers USA, May 3, 2018
•18 Caplin & Drysdale Attorneys Recognized by Super Lawyers in D.C., April 23, 2018
•Bloomberg BNA Quotes Patricia Lewis: Safe Harbors for Cost Sharing a Lesson from Amazon, Bloomberg BNA, July 21, 2017
•Patricia Lewis Discusses Advance Pricing Agreements with Bloomberg BNA, Bloomberg BNA, May 16, 2017
•Bloomberg BNA Quotes Patricia Lewis on New IRS Appointment, Bloomberg BNA, April 12, 2016
•International Tax Monitor Quotes Patricia Lewis on Advance Pricing Agreements, Daily Tax Report and International Tax Monitor, August 12, 2015
•Patricia Lewis Discusses OECD Discussion Draft at Transfer Pricing Conference, International Tax Monitor, June 12, 2015
•Patricia Lewis Named Best in Transfer Pricing for 2014, International Financial Law Review, Americas Women in Business Law Awards, June 5, 2014
•Transfer Pricing Weekly Quotes Patricia Lewis Regarding IRS Proposals to Revise APA and MAP Procedures, Transfer Pricing Weekly, April 3, 2014
•Patricia Lewis Analyzes Proposed Revisions to U.S. APA and Competent Authority Procedures, Tax Analysts, March 10, 2014
•Tax Analysts' Worldwide Tax Daily Quotes Patricia Lewis: Proposed U.S. Competent Authority Procedures Could Complicate Issue Resolution, Tax Notes, February 13, 2014
•Patricia Lewis Comments on Concerns Over Revised APA and Competent Authority Procedures, Tax Notes, December 13, 2013
•Patricia Lewis Moderates Transfer Pricing Panel Discussion, Bloomberg, July 15, 2013
•Tax Notes Quotes Patricia Lewis Regarding New OECD Transfer Pricing Safe Harbor Guidelines, Tax Notes, May 22, 2013
•Patricia G. Lewis Discusses Bilateral Safe Harbors in Tax Management Transfer Pricing Report, Tax Management Transfer Pricing Report, November 29, 2012
•Patricia Gimbel Lewis Wins Best in Transfer Pricing Award, Women in Business Law Awards for the Americas, Euromoney Legal Media Group, May 25, 2012

Areas of Practice (5)

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

Education & Credentials

Contact Information:
(202) 862-5017  Phone
University Attended:
Wellesley College, B.A., Durant Scholar, 1966; Harvard University, M.B.A., with high distinction, Baker Scholar, 1971
Law School Attended:
Harvard Law School, J.D., cum laude, 1971
Year of First Admission:
U.S. Tax Court; U.S. District Court for the District of Columbia; U.S. Court of Appeals for the District of Columbia Circuit; 1971, Massachusetts; 1974, New York; 1972, District of Columbia; U.S. Claims Court

Other Professional Affiliations

Member, 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

Co-Chair, IRS/George Washington University Institute on Current Issues in International Taxation, 2000-2001; Member, Advisory Board, 1995-Present

Member, District of Columbia Bar, Taxation Section

Professional Activities

•Member, United States Council for International Business (USCIB), 2013-Present
•Co-Chair, Steering Committee, D.C. Bar Taxation Section, 1992-1995
•Member, IRS Commissioner's Advisory Group, 1994-1996


Peer Reviews

A Martindale-Hubbell Peer Rating reflects a combination of achieving a Very High General Ethical Standards rating and a Legal Ability numerical rating.

*Peer Reviews provided before April 15, 2008 are not displayed.

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