Mark J. Silverman

Partner

1330 Connecticut Avenue, NW
Washington DC 20036
TEL: 202.429.6450
FAX: 202.429.3902

Mark J. Silverman is a partner in the Washington office of Steptoe & Johnson LLP, where he heads Steptoe's tax practice. Mr. Silverman was named one of the top ten tax lawyers in Washington in 2005 by Legal Times. He is a member of The American Law Institute, Tax Advisory Group for the Study of Subchapter C of the Internal Revenue Code. He was formerly an advisor to the Committee on Ways and Means during their consideration of revisions to the corporate tax provisions of the Internal Revenue Code. He is a Fellow of the American College of Tax Counsel. Mr. Silverman was formerly a Council member of the American Bar Association, Section of Taxation and was formerly Chair of the Corporate Tax Committee. He chaired the Tax Section Task Force on Leveraged Buyouts. Mr. Silverman co-authored the Tax Advisors Planning Series on Financially Troubled Businesses, he was formerly Corporate Tax Editor of The Journal of Taxation, and is a member of the advisory boards of NYU Institute on Federal Taxation, BNA Tax Management, Consolidated Returns Tax Report, M&A Tax Report, and Corporate Taxation magazines. Mr. Silverman is on the Editorial Board of The American Journal of Tax Policy, and is on the Board of Trustees of the Southern Federal Tax Institute. Mr. Silverman chairs the ALI-ABA annual consolidated returns program. Mr. Silverman was formerly a member of the Executive Committee of the New York State Bar Association. In addition, he is an Adjunct Professor of Law at Georgetown University Law Center and was formerly attorney-advisor to Judge Samuel B. Sterrett of the United States Tax Court. Mr. Silverman is a frequent speaker on tax matters and has published numerous articles on the subject.

Planning & Transactional Practice
Mr. Silverman focuses on planning and transactional matters. He has extensive experience in structuring acquisitions, mergers, and spin-off transactions for large public corporations, as well as closely held businesses. He has authored a book on the tax consequences of financially troubled businesses and advises corporations on consolidated return issues. Mr. Silverman advises leverage buyout groups, venture capitalists and privately held commercial real estate developers with respect to various transactional matters. He is often called upon to advise the Internal Revenue Service, Treasury Department, and the staffs of the Congressional tax writing committees with respect to corporate tax issues.

Tax Policy Practice
A significant part of Mr. Silverman's practice involves the resolution of tax policy issues before Congress and the Treasury Department. These issues arise in the context of pending or proposed legislation and proposed Treasury Department regulations. Mr. Silverman is currently meeting with members of Congress and their staffs on many of the corporate tax provisions proposed by the Administration and by members of Congress (including corporate spin-offs, financial product provisions, and corporate capital gains).

Audit & Controversy
Mr. Silverman also handles audit and controversy matters. He has extensive experience negotiating with field agents, appeals officers and district counsel in settling significant audit issues. Mr. Silverman frequently prepares technical advice requests and often meets with National Office officials with respect to audit and tax litigation matters.

Recently, Mr. Silverman was successful in negotiating global tax shelter settlements with the IRS.

Noteworthy

Ranked, Chambers Global 2008 - 2010: The World's Leading Lawyers for Business — Tax: Corporate (US)
Received a #1 Ranking, Chambers USA 2010: America's Leading Business Lawyers; Tax (District of Columbia)
Distinguished as a Top 100 attorney in Washington, DC Super Lawyers
Listed in Washington, DC Super Lawyers 2007—2010
Listed in Best Lawyers in America 2010 for Corporate Law, Mergers & Acquisitions Law and Tax Law
Mentioned in Legal 500 US 2008-2010 for Tax
Recommended by Practical Law Company for Tax (USA) and Tax (Washington DC)
Listed in Who's Who Legal for Corporate Tax in 2007-2009
Listed among the "Top Lawyers in Washington" by Washingtonian, 2009
Ranked, PLC Cross-border Tax on Corporate Transactions Handbook 2008/09
Named Among the “Top Ten Tax Lawyers in Washington, DC” by Legal Times, 2005
Former advisor to Committee on Ways & Means Counsel, ABA, Tax Section
Chair, Corporate Tax Committee, ABA, Tax Section
Advisory Board Member, NYU Institute and BNA Tax Management
Member, Board of Trustees, Southern Federal Tax Institute
Adjunct Professor, Georgetown University Law Center
Chair, ALI-ABA Consolidated Returns Program
Advisor to the Federal Bar Association Section of Taxation Law Conference
Co-author of Tax Advisors Planning Series on Financially Troubled Businesses
Former attorney-advisor to Judge Samuel B. Sterrett of US Tax Court

Select News & Events

Selected Publications

Current Developments in Corporate Tax
Denver, CO
July 22, 2010, 60th Annual Tax Institute
Regulations Governing Intercompany Transactions Within Consolidated Groups
2010
The Economic Substance Doctrine
San Francisco, CA
June 18, 2010, PLI Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2010
Current Developments in Tax-Free and Taxable Acquisitions and Separations
2010
A New Form of Obscenity? Sorting through the Federal Circuit’s “We Know It When We See It” Ruling in Coltec
2010
Assessing the Value of the Proposed "No Net Value" Regulations
2010
Comparison of the Intercompany Obligation Rules Under Former Treas. Reg. § 1.1502-13(g) (1995), Former Prop. Treas. Reg. § 1.1502-13(g) (1998), and Treas. Reg. § 1.1502-13(g) (2008)
2010
Consolidated Return Loss Disallowance and Loss Duplication Rules
June 2010

More Publications »