Philip R. West

Partner

• pwest@steptoe.com
• vCard
• Washington Office

Philip R. West is a partner in the Washington office of Steptoe & Johnson LLP, where he focuses mainly on international tax issues for both domestic and foreign clients. Mr. West also serves on Steptoe's Strategic Planning and Diversity Committees, and is a past member of the firm's Executive Committee.

With 25 years in practice, Mr. West has extensive practical experience minimizing the tax cost of international business operations and transactions. He has deep substantive knowledge of income deferral, foreign tax credit, transfer pricing, and tax treaty matters, as well as the tax aspects of mergers, acquisitions, joint ventures, and financings, investment funds, and tax minimization structures and transactions. He also devotes significant attention to helping clients favorably resolve controversies with, and obtain rulings from, the IRS, and he has been particularly active with competent authority matters and with attest auditors on FIN 48 and other financial statement issues. Mr. West also has extensive practical experience dealing with the Treasury Department and Congress on both technical matters and on issues of broad policy significance.

Mr. West served for nearly four years as the Treasury Department’s International Tax Counsel, the senior international tax lawyer in the US government. In that position, he played a central role in virtually every policy, legislative, and regulatory development in the international tax area and led tax treaty negotiations, discussions, and ratification efforts involving countries throughout the world. Mr. West also played a major role in the US work at the Organization for Economic Cooperation and Development (OECD) and led official delegations there and on other missions. He has practical experience with many foreign tax systems and good relationships with foreign tax officials and private practitioners around the world. He is regularly called on to advise government officials with respect to sensitive and complex tax matters.

Earlier in his career, Mr. West litigated tax cases with the Justice Department, advised Judge Carolyn Miller Parr as a Tax Court clerk, counseled financial institutions and other clients with a Wall Street law firm, and practiced in the national office of an international accounting firm.

Mr. West is a frequent speaker and author on international and domestic tax subjects, addressing both professional and academic audiences.

Noteworthy

• Received #1 Ranking in Chambers Global 2008 - 2010: The World’s Leading Lawyers for Business—Tax: International Tax (US) 
• Listed in Washington, DC Super Lawyers 2007-2010
• Ranked, Chambers USA 2010: America’s Leading Business Lawyers—Tax (District of Columbia)
• Mentioned in Legal 500 US 2010 for Tax
• Best Lawyers in America 2006-2010 for Tax Law
• Recommended by Practical Law Company for Tax, Washington DC
• Who’s Who Legal for Corporate Tax in 2007-2009
• International Tax Review's "World Tax 2007," "acknowledged as the star of Steptoe & Johnson's tax practice"
• PLC Which Lawyer? Yearbook 2008 for Tax
• Recommended by Legal 500 US 2008 for Tax: Domestic Tax - East Coast
• Fellow, American College of Tax Counsel 
• US Treasury Department, Exceptional Service Award, 2000
• ABA Tax Section Foreign Lawyers Forum, Vice-Chair, 2002-present
• NYSBA, Executive Committee and Chair of International Tax Committees, 1991-1996
• Congressional Working Group on Int’l Tax Reform, Advisor, 2002
• ABA Task Force on International Tax Reform, 2002-2006
• International Fiscal Association Council, 2004-present
• ABA Review Committee on Government Submissions, 2006-present
• IRS/NYU Prof. Ed. Program, Board Member, 2001-2004
• IRS/GWU Institute on Int’l Taxation, Board Member, 2006-2008
• Adjunct Professor, 1997-1999, Georgetown University Law Center
• Guest Lecturer, 1993-1996, 2004-present, Harvard, University of Michigan, and NYU Law Schools
• Steptoe International Tax Team Advises on Private Equity Acquisitions
• Steptoe International Tax Team Helps Favorably Resolve IRS Audits of Complex Tax-Sensitive Structures
• Steptoe International Tax Team Obtains 100% Concession from IRS on Transfer Pricing Issue Regarding Cross-Border Services
• Steptoe International Tax Team Obtains 100% Relief from Foreign Tax Authorities in Competent Authority Agreement on Thin Capitalization Issue
• Steptoe International Tax Team Obtains Groundbreaking Competent Authority Agreement with Japan
• Steptoe International Tax Team Obtains Important Regulatory Clarification under Homeland Investment Repatriation Provisions
• Steptoe Advises Stratos on Xantic Acquisition

Select News & Events

• Phil West Speaks at International Fiscal Association Annual Meeting, August 30, 2010
• Legal 500 US Honors Seven Practices and 23 Attorneys from Steptoe
• Chambers USA Honors 18 Steptoe Practices and 41 Attorneys
• Philip West Addresses Panel at Joint Meeting of the USA and Brazil Branches of the International Fiscal Association, May 18, 2010
• Philip West Addresses Wall Street Tax Association’s Spring Tax Seminar, May 17, 2010
• Phillip West to be Moderator at American Bar Association Section of Taxation Panel, May 7, 2010
• Marketplace Morning Report Interviews Phil West on Proposed Bank Tax
• Chambers Global Honors Nine Steptoe Practice Areas and 20 Attorneys
• Super Lawyers Honors 24 Steptoe Attorneys
• Philip West Speaks at International Fiscal Association Conference, February 25, 2010
• Philip West and Michael Durst Speak at the Tax Executives Institute International Tax Seminar, February 12, 2010
• Best Lawyers in America Honors 44 Steptoe Attorneys

Selected Publications

• LegalEase: Plain Talk on Legal Topics - Strip Search
  March 2010, LeadersEdge
• Comparative Anti-Abuse Tax Rules and Policy: Emerging Coherence or a Tower of Babel?
  March 2008, Tax Notes International
• Letter Regarding Foreign Tax Credit Arbitrage and Leveraged Foreign Investment
  2006
• Obtaining and Providing Outside International (and Other) Tax Advice in the Current Tax Enforcement and Compliance Environment
  October 1, 2005
• News Analysis: Pasquantio Case Raises International Planning Concerns
  May 30, 2005
• Re-Thinking Check-the-Box: Subpart F
  March 1, 2005
• Impact of American Jobs Creation Act, Long Term Capital Holdings, Black & Decker, Coltec, TIFD III-E and Other Tax Shelter Developments
  November 2004
• Establishing Business Purpose in a Transparent World
  May 14, 2004

More Publications »