Overview
Amanda Varma advises multinational businesses on US federal income tax matters, with particular focus on international tax planning, controversies, and tax policy issues. She counsels both US- and foreign-owned businesses across a variety of industries, regularly advising on the US tax consequences of cross-border investments, business restructurings, supply chain issues, and intellectual property transactions. Her work includes representing clients before the Internal Revenue Service in obtaining private letter rulings and other determinations as well as advocating for regulatory and other policy changes before the U.S. Department of the Treasury. Amanda also represents clients in IRS controversies and regularly advises clients on special issues arising in international tax controversies, including competent authority and information exchange issues.
Amanda is an Adjunct Professor of Law in the Graduate Tax Program at the Georgetown University Law Center, where she teaches US International Inbound Tax, a course focusing on the US taxation of foreign persons investing in the United States. She also frequently speaks and writes on international tax issues, including writing a regular "Leading Practitioner" column for BNA Tax Management International Journal. She also serves as the chair of the International Tax Committee of the DC Bar Tax Community.
Amanda also is the chair of the American Bar Association Women in Tax Forum. She is also the former chair of Steptoe's Women's Forum and the former president of the Coalition of Women’s Initiatives in Law – Washington, D.C. chapter.
- District of Columbia
- California
- US Court of Appeals, Second Circuit
- US Tax Court
- J.D., University of Michigan Law School, 2007, magna cum laude; Executive Editor, Michigan Law Review
- B.A., University of California, Berkeley, 2004, with high distinction; Phi Beta Kappa
Areas of Work
Speaking Engagements
- "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 37th 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
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"Nonresident Alien and Foreign Business Tax Compliance: Critical Tax Presence and Residency Issues," Strafford Webinar, July 16, 2020
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Moderator, "Cross-Border Individual Matters," GW/IRS Annual Institute on Current Issues in International Taxation, December 19, 2019
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"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
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"New International Reporting & Compliance Requirements, Post-TCJA," Tax Executive Institute Annual Conference, October 29, 2019
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"Recent IRS Guidance re BEAT, FDII, GILTI, Captive Services: Technical Update," NABE Transfer Pricing Symposium, July 16, 2019
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"What Every Foreign Investor Should Know? The Changing Landscape of US Inbound Investment," IFA USA Atlanta Region Spring Seminar, June 14, 2019
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Moderator, "Presumed GILTI?," FBA Insurance Tax Seminar, May 30, 2019
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Moderator, "What's My Purpose: The Practical Implications of the Principal Purpose Test," ABA Section of Taxation 2019 May Tax Meeting, May 11, 2019
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"Discretionary Treaty Benefits," ABA Section of Taxation 2019 May Tax Meeting, May 10, 2019
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"The FDII and GILTI Deduction Proposed Regulations," DC Bar Taxation Community International Tax Series, March 26, 2019
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"Cross-Border Individual Matters," GW/IRS Annual Institute on Current Issues in International Taxation, Washington, DC, December 13, 2018
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"Tax Reform Guidance Update," Tax Executive Institute Virginia Chapter December Meeting, December 4, 2018
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"The New Paradigm II - The Foreign Tax Credit," Tax Executive Institute Annual Conference, October 29, 2018
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Moderator, "BEAT - Not for the Faint of Heart," ABA Tax Section 2018 Fall Meeting, October 5, 2018
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"Cross Border Individual Matters," GW/IRS Tax Institute, November 30, 2017
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"Managing Tax-Related Whistleblowers, Leaks and Derivative Suites," American Bar Association, October 27, 2017
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"Outbound Guidance: News of Its Death? Exaggerated," American Bar Association, September 15, 2017
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"Section 367 Current Developments," DC Bar, February 28, 2017
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"Inbound Developments," GW/IRS 29th Annual Institute on Current Issues in International Taxation, December 16, 2016
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"Information Sharing: Rules, Practices, and the Role of the Taxpayer," American Bar Association, October 28, 2016
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"Current Tax Legislation Considerations from View of Government Affair Representatives," Federal Bar Association 28th Annual Insurance Tax Seminar, June 2, 2016
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"International Tax Series: Recent Guidance on Partnerships and Subpart F," DC Bar, October 29, 2015
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"Current Federal Income Tax Developments, Including Those Affecting Financial Products," Institute of International Bankers, June 16, 2015
News & Publications
Client Alerts
Controversial Disregarded Payment Loss Rules Finalized, With Some Relief
January 13, 2025
Publications
2025 Transfer Pricing Report: Global Review & USA
Lexology: Panoramic Guide
August 22, 2024
Publications
IRS Transfer Pricing Memo on Implicit Support Has Legal Flaws
Bloomberg Law
March 5, 2024
Publications
PTEP: Recent Guidance on Inbound Transactions and Looking Ahead
Bloomberg Tax Management International Journal
January 17, 2024
Client Alerts
Transfer Pricing GLAM on Implicit Support Raises Many Questions, Offers Few Answers
January 9, 2024
Publications
Foreign Tax Credit Considerations After Notice 2023-55
Bloomberg Tax Management International Journal
September 21, 2023
International Compliance Blog
August 2, 2023
By: Quentin Johnson, Wendy Wysong, Jack R. Hayes, Amanda Pedvin Varma, Edward J. Krauland, David M. Stetson
Events
Seminars & Events
Year End Tax Conference and Celebration
December 6, 2021
Speakers: Alan Cohn, Micah S. Green, Zvi Hahn, Lawrence Hill, Aaron P. Nocjar, Caitlin R. Tharp, Beth D. Tractenberg, Amanda Pedvin Varma, Philip R. West, Lisa M. Zarlenga
Webinars
Business Tax Proposals in President's FY22 Budget
June 4, 2021
Speakers: Amanda Pedvin Varma, Lisa M. Zarlenga
Webinars
November 10, 2016
Speakers: Jason Abel, Leslie A. Belcher, Elizabeth Hurley Burks, Micah S. Green, N. Hunter Johnston, Darryl Nirenberg, Scott A. Sinder, Amanda Pedvin Varma
Noteworthy
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Legal 500 US, Tax: International Tax (2013-2015, 2017-2019)
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Legal 500 US, Tax: US Taxes, non-contentious (2018)
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Legal 500 US, Tax: Tax Controversy (2014-2015)
Professional Affiliations
- 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