Amanda Pedvin Varma

Dispute Resolution (Including MAP and APAs)

• Represented large US multinational in APA involving intercompany sales, services, and business restructuring.
• Represented US group in MAP and APA proceedings and related international tax issues.
• Advised major non-US technology company in APA involving cost-sharing arrangement.
• Represented non-US multinational in MAP with respect to IRS transfer pricing adjustment.
• Represented major US technology company in major controversy involving transfer pricing, foreign tax credit, and other international tax issues.

Advisory

• Advised large multinational client on cross-border restructuring and successfully obtained guidance addressing critical international tax aspect of restructuring.
• Advised several non-US multinationals on tax treaty issues, including qualification for benefits, permanent establishment, and withholding tax issues.
• Represented several foreign-headquartered clients in requests for discretionary treaty benefits.
• Counseled multiple clients on transfer pricing, foreign-derived intangible income (FDII), subpart F, and other tax issues implicated by potential changes to supply chain.
• Advised multiple clients on technical issues related to foreign tax credits and expense allocation.
• Advised multiple non-US companies on consequences of potential expansion of business activities to the United States.
• Advised leading consumer products company on permanent establishment and transfer pricing aspects of supply chain restructuring.
• Advised multiple high-net-worth individuals and family offices on issues such as residency, pre-immigration planning, and voluntary disclosures.

Tax Policy

• Successfully advocated for change to foreign tax credit rules on behalf of insurance company clients.
• Represented financial services client in successfully advocating for changes to section 163(j) regulations.
• Counseled foreign trade association on US tax treaty policy issues.
• Successfully represented financial services trade association in obtaining changes to Foreign Account Tax Compliance Act (FATCA).

• "Foreign Tax Credits (FTCs) and Subpart F Planning and Developments,"” International Tax Issues 2025, January 28, 2025
• "Cross-Border Acquisitions and Divestitures," PLI’s 2024 Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings,  November 13, 2024
• "Source of Income, and Allocation and Apportionment of Expenses," Practising Law Institute's Basics of International Taxation 2023, July 20, 2023
• "Current Developments in Inbound International Tax and Treaties," ABA Section of Taxation May Meeting, May 5, 2023
• "Are Your Foreign Tax Credits Lost?" ABA Section of Taxation May Meeting, May 5, 2023
• “Foreign Tax Credits and Subpart F Planning and Developments,” Practising Law Institute's 2023 International Tax Issues, January 2023
• "Cross-Border Partnership Issues," Florida Bar/FICPA International Tax Conference, Jan. 12, 2023
• “Subpart F and Other Anti-Deferral Developments, GW/IRS Annual Institute on Current Issues in International Taxation, December 15, 2022
• "Cross-Border Acquisitions and Divestitures," Practising Law Institute's 2022 Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings Program, October 2022
• “Source of Income, and Allocation and Apportionment of Expenses,” Practising Law Institute’s Basics of International Tax Conference, September 2022
• "International Joint Venture Issues," PLI's Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2022 Program, June 8, 2022
• "International Tax – Current Inbound Insurance Issues," Federal Bar Association’s 37^th Annual Insurance Tax Seminar, June 2, 2022
• "Hot topics in Section 382 and Troubled Companies," ABA Section of Taxation May Meeting, May 14, 2022
• "FTC – "A Deeper Dive into the Muddy Waters," ABA Section of Taxation May Meeting, May 13, 2022
• "Tax Challenges Arising from Digitalization – Pillar I," IFA Webinar, May 11, 2022
• "The Changing Face of US Investment Into Europe," ABA Virtual 22nd Annual US and Europe Tax Practice Trends Conference, March 31, 2022
• "The Foreign Tax Credit Final Regulations – an Overview and Discussion of Key Provisions," IFA USA Webinar, February 2, 2022
• "Implementation of the Pillar II Globe rules in the European Union and US," University of Lausanne's Global Minimum Tax Agreement Conference, January 28, 2022
• "Recent Developments and Trends in Corporate Taxation Planning," USC Gould School of Law 2022 Tax Institute, January 24, 2022
• "Impact of Two-Pillar Solution on Multinationals," Inteli-luris Webinar, December 3, 2021
• "Cross-Border Acquisitions and Divestitures," Practising Law Institute's 2021 Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings Program, October 26, 2021
• "US International Tax Controversies: Procedural and Substantive Developments," Tax Executive Institute Annual Conference, October 25, 2021
• "GILTI (Dis)pleasure – Technical Discussion of how the Biden Administration Proposed Tax Legislative Changes will Impact International Provisions," ABA Tax Section 2021 Fall Meeting, September 22, 2021
• "Taxation on Blockchain," IFA Webinar, August 25, 2021
• "Ethics, Diversity, and Inclusion in Tax and the Tax Department," Federal Bar Association's Insurance Tax Seminar, May 28, 2021
• "Biden International Tax Plan," Wall Street Tax Association 2021 Spring Tax Conference, May 19, 2021
• "US Tax Treatment of Hybrid Entities and Transactions: Sections 267A and 245A(e) Regulations," Strafford Webinar, March 25, 2021
• "Cross-border Hybrid Instruments and Transactions," 2021 Florida Tax Institute, March 11, 2021
• "Final and Proposed Regulations: Repeal of Section 958(b)(4)," IFA USA Webinar, October 8, 2020
• "US Activities of Foreigners & Tax Treaties," ABA Tax Section 2020 Fall Meeting, October 2, 2020

• "Nonresident Alien and Foreign Business Tax Compliance: Critical Tax Presence and Residency Issues," Strafford Webinar, July 16, 2020

• Moderator, "Cross-Border Individual Matters," GW/IRS Annual Institute on Current Issues in International Taxation, December 19, 2019

• "Impact of 2017 Tax Act on Cross-Border Acquisitions and Divestitures," PLI's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2019, December, 5, 2019

• "New International Reporting & Compliance Requirements, Post-TCJA," Tax Executive Institute Annual Conference, October 29, 2019

• "Recent IRS Guidance re BEAT, FDII, GILTI, Captive Services: Technical Update," NABE Transfer Pricing Symposium, July 16, 2019

• "What Every Foreign Investor Should Know? The Changing Landscape of US Inbound Investment," IFA USA Atlanta Region Spring Seminar, June 14, 2019

• Moderator, "Presumed GILTI?," FBA Insurance Tax Seminar, May 30, 2019

• Moderator, "What's My Purpose: The Practical Implications of the Principal Purpose Test," ABA Section of Taxation 2019 May Tax Meeting, May 11, 2019

• "Discretionary Treaty Benefits," ABA Section of Taxation 2019 May Tax Meeting, May 10, 2019

• "The FDII and GILTI Deduction Proposed Regulations," DC Bar Taxation Community International Tax Series, March 26, 2019

• "Cross-Border Individual Matters," GW/IRS Annual Institute on Current Issues in International Taxation, Washington, DC, December 13, 2018

• "Tax Reform Guidance Update," Tax Executive Institute Virginia Chapter December Meeting, December 4, 2018

• "The New Paradigm II - The Foreign Tax Credit," Tax Executive Institute Annual Conference, October 29, 2018

• Moderator, "BEAT - Not for the Faint of Heart," ABA Tax Section 2018 Fall Meeting, October 5, 2018

• "Cross Border Individual Matters," GW/IRS Tax Institute, November 30, 2017

• "Managing Tax-Related Whistleblowers, Leaks and Derivative Suites," American Bar Association, October 27, 2017

• "Outbound Guidance: News of Its Death? Exaggerated," American Bar Association, September 15, 2017

• "Section 367 Current Developments," DC Bar, February 28, 2017

• "Inbound Developments," GW/IRS 29th Annual Institute on Current Issues in International Taxation, December 16, 2016

• "Information Sharing: Rules, Practices, and the Role of the Taxpayer," American Bar Association, October 28, 2016

• "Current Tax Legislation Considerations from View of Government Affair Representatives," Federal Bar Association 28th Annual Insurance Tax Seminar, June 2, 2016

• "International Tax Series: Recent Guidance on Partnerships and Subpart F," DC Bar, October 29, 2015

• "Current Federal Income Tax Developments, Including Those Affecting Financial Products," Institute of International Bankers, June 16, 2015

• Legal 500 US, Tax: International Tax (2013-2015, 2017-2019)

• Legal 500 US, Tax: US Taxes, non-contentious (2018)

• Legal 500 US, Tax: Tax Controversy (2014-2015)

• Adjunct Professor of Law, Georgetown University Law Center (2018-present)
• Chair, International Tax Community of DC Bar Tax Committee (2021-present)
• Chair, American Bar Association Women in Tax Forum (2021-present)
• President, Coalition of Women's Initiatives in Law, Washington, DC Chapter (2021-2022)
• Fellow, Leadership Council on Legal Diversity (2020)
• Member, American Bar Association Tax Committee
• Member, International Fiscal Association