Steven P. Hannes

AV stamp icon
  • Senior Counsel at Caplin & Drysdale, Chartered (67 Attorneys)
  • One Thomas Circle NW, Suite 1100, Washington, DC 20005
    View Steven P. Hannes's office location
  • Peer Reviews

  • Profile Visibility [ i ]
Attorney Awards


Steven P. Hannes is Senior Counsel to Caplin & Drysdale's International Tax and Tax Controversies practice groups. Mr. Hannes joined the firm in March 2018.

Government Experience

Associate International Tax Counsel, Office of the Assistant Secretary (Tax Policy), U.S. Department of Treasury

Chief, International Rulings Group, Office of the Assistant Commissioner (Technical), Internal Revenue Service


Mr. Hannes advises U.S.- and foreign-based multinational corporations on developing their cross-border transactions, and counsels multinational companies in tax controversies. He represents clients on matters at the Audit, Appeals, Competent Authority and the Advance Pricing Agreement offices of the Internal Revenue Service (IRS). Mr. Hannes is recognized nationally for creating and defending structures and contractual arrangements that involve intra-group transactions and prices for intellectual property, goods and services. He has also presented expert testimony on tax treaties in court.

Mr. Hannes counsels clients in a range of industries, including automotive, heavy machinery, pharmaceuticals and chemicals, computers and electronics, and consumer goods such as beverages and photo equipment. He also advises clients involved in research, technical, and other services.


Mr. Hannes served as associate international tax counsel in the Office of the Assistant Secretary (Tax Policy) of the U.S. Treasury Department. He helped negotiate income tax treaties and protocols with, among others, the governments of Canada and the United Kingdom. Before joining Treasury, Mr. Hannes was chief of the international rulings group in what was then called the Office of the Assistant Commissioner (Technical) of the IRS.

Mr. Hannes speaks frequently at international and national conferences, and has authored many articles on international tax topics.

Recent Publications

•Do Theories Trump Facts Under the U.S. Arm's Length Standard? Is the BEPS Pricing Guidance on Intangibles Consistent with the U.S. Law?, BNA Tax Management Transfer Pricing Report, March 17, 2016
•Tax Court Decision in Altera Overturns Important Transfer Pricing Regulations, The National Law Review, October 2, 2015
•Transfer Pricing Discussion Group ( TPDG ) Comments on Organisation for Economic Co-Operation ( OECD ) BEPS Initiatives on Transfer Pricing, Tax Notes Today: Special Report, June 30, 2015
•TPDG Comments on OECD Discussion Draft on Transfer Pricing Documentation and CbC Reporting, March 10, 2014
• CHAPTER 5: Comparable Uncontrolled Price (CUP) Method, Practical Guide to U.S. Transfer Pricing, December 15, 2006
• The Attribution of Profits to Permanent Establishments, Report of the United States Branch of the IFA, Cahiers de Droit Fiscal International, Volume 91b, January 1, 2006

Awards & Rankings

Best Lawyers in America, Litigation and Controversy - Tax, Tax Law, 2007-Present
Expert Guides' The Best of the Best, Tax Advisors for Transfer Pricing
International Who's Who of Business Lawyers
International Who's Who of Corporate Tax Lawyers
The Legal 500

Recent News

•Caplin & Drysdale Improves Ranking in 2019 Best Lawyers in America, August 15, 2018
•Caplin & Drysdale Welcomes Steven Hannes to Its International Tax Group, Caplin & Drysdale, March 5, 2018

Areas of Practice (2)

  • International Tax
  • Tax Controversies

Education & Credentials

Contact Information:
(202) 862-5020  Phone
202-756-8087  Fax
University Attended:
Amherst College, B.A., 1967
Law School Attended:
New York University School of Law, J.D., 1970
Year of First Admission:
District of Columbia

Other Professional Affiliations

Member and Past President, Executive Committee, International Fiscal Association

Founder and Chair, Transfer Pricing Discussion Group

Former Chairman, International Taxation Committee, American Bar Association, Business Law Division

Member, Washington International Tax Study Group

Birth Information:
February 3, 1945

Peer Reviews

  • 5.0/5.0
  • 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.

Washington, District of Columbia

Contact Steven P. Hannes

Required Fields

Required Fields

By clicking on the "Submit" button, you agree to the Terms of Use, Supplemental Terms and Privacy Policy. You also consent to be contacted at the phone number you provided, including by autodials, text messages and/or pre-recorded calls, from Martindale and its affiliates and from or on behalf of attorneys you request or contact through this site. Consent is not a condition of purchase.

You should not send any sensitive or confidential information through this site. Emails sent through this site do not create an attorney-client relationship and may not be treated as privileged or confidential. The lawyer or law firm you are contacting is not required to, and may choose not to, accept you as a client. The Internet is not necessarily secure and emails sent though this site could be intercepted or read by third parties.