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 Executive Committee, Strategic Planning Committee, and Diversity Committee.

With almost 25 years as a tax lawyer, Mr. West has extensive practical experience minimizing the tax cost of international business operations and transactions. He also devotes significant attention to helping clients favorably resolve difficult matters with the IRS at the National Office, appeals, and exam levels. He has also been particularly active recently with competent authority matters and with attest auditors on FIN 48 and other financial statement issues.

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. And he is regularly called on to advise government officials with respect to sensitive and complex tax matters.

Mr. West 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. 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; and interacting with the IRS and the courts on audits, controversies, and rulings. For his entire professional career, Mr. West has worked on all sides of the tax shelter issue, setting policy on tax shelter issues as a Treasury Department official, litigating tax shelter cases with the Justice Department, advising Judge Carolyn Miller Parr on tax shelter cases as a Tax Court clerk, counseling financial institutions on structured products issues with a Wall Street law firm, evaluating tax shelters and structured products with an international accounting firm, and representing investors and intermediaries while at Steptoe.

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

Noteworthy

• #1 Ranking in Chambers Global 2008, The World’s Leading Lawyers for Business, US Tax: International Tax
• Chambers USA 2007, America’s Leading Business Lawyers; Tax (District of Columbia)
• International Tax Review's "World Tax 2007," "acknowledged as the star of Steptoe & Johnson's tax practice"
• Best Lawyers in America 2006-2008 for Tax Law
• PLC Which Lawyer? Yearbook 2008 for Tax
• Super Lawyers 2007 for Tax, Washington, DC
• Who’s Who Legal for Corporate Tax in 2007-2008
• 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

Success Stories

• 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

News

• Best Lawyers in America Honors 43 Steptoe Attorneys
• 18 Steptoe Attorneys Selected for Who's Who Legal
• Chambers and Partners Names Steptoe A Leading Firm in 22 Practice Areas
• 17 DC Attorneys Listed in Super Lawyers 2007
• Best Lawyers in America 2007 Lists Steptoe Attorneys
• Over 20 Make 2007 Best Lawyers in America: DC List

Publications

• 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
• Foreign Law in US International Taxation: The Search for Standards
  July 1, 1996
  Florida Tax Review