Steptoe advises global businesses and high-net-worth individuals across all industries on their most important and complex international tax matters. Our work includes counseling clients on sophisticated tax planning, advising on transactions, resolving disputes with taxing authorities and in court, and helping clients obtain published and private guidance from the IRS and the US Department of the Treasury. We regularly advise on special issues arising in international tax disputes, including competent authority and information exchange.
Our lawyers are recognized as leaders in the international tax field and speak regularly at tax conferences, teach in top tax programs, and write on international tax issues. Because we assist clients on their most significant and often high-profile matters, we are experienced in working effectively and efficiently with teams of advisors, including other Steptoe lawyers, local counsel, accounting firms, and economists. We are committed to solving clients’ problems with practical judgment, technical skill, professionalism, and integrity.
Noteworthy
- Chambers USA, Tax: Corporate & Finance, Nationwide (2009-2023)
- Chambers USA, Tax: Controversy, Nationwide (2008-2023)
- Chambers USA, Tax, DC (2006-2023)
- Legal 500 US, Tax: International (2011-2023)
- Legal 500 US, Tax: US Tax: Contentious (2009-2023)
- Legal 500 US, Tax: US Tax: Non-Contentious (2009-2023)
Representative Matters
- Successfully advocated on behalf of defense contractor for industry-specific guidance under foreign-derived deduction intangible (FDII) rules.
- Counseled multinational clients with respect to base erosion and anti-abuse tax (BEAT).
- Represented foreign financial institution in connection with successful request for discretionary treaty benefits.
- Advised multiple high-net-worth individuals and family offices on issues such as residency, pre-immigration planning, and voluntary disclosures.
- Advised US technology company on US tax consequences of reorganization transaction.
- Successfully argued on behalf of Puerto Rico before the US Treasury Department and IRS in connection with the release of Notice 2011-29 regarding the creditability of Puerto Rico's new excise tax.
- Obtained favorable IRS guidance pertaining to qualified dividend rules.
- Represented a large financial institution in connection with a major controversy involving transfer pricing of derivatives transactions.
- Represented a Middle Eastern investment company in groundbreaking Competent Authority resolution of high value and seemingly intractable dispute.
News & Publications
Media Mentions
The American Tax Policy Institute Submits US Supreme Court Amicus Brief in Moore v. United States
October 12, 2023
Publications
Foreign Tax Credit Considerations After Notice 2023-55
Bloomberg Tax Management International Journal
September 21, 2023
Client Alerts
July 12, 2023
Press Releases
Steptoe Receives 28 Practice Rankings, 34 Individual Awards in Legal 500 US 2023
June 14, 2023
Press Releases
Caitlin Tharp Named a 2023 - 2024 John S. Nolan Fellow by ABA Section of Taxation
May 23, 2023
Client Alerts
BE-12 Report Filing Deadline Approaches for Foreign Investments in US Real Estate
February 28, 2023
Press Releases
Steptoe Receives 16 Practice, 40 Individual Mentions in Chambers Global 2023
February 21, 2023
Publications
The Book Minimum Tax Foreign Tax Credit: New and Lingering Issues
Bloomberg Tax’s Tax Management International Journal
October 7, 2022
Events
Resources
Client Alerts
European Public Prosecutor to Take EU Finance Fraudsters to Task?
April 28, 2020
By: Zoe Osborne
Daily Tax Update
IRS Issues Final Regulations for Public Approval of Tax-Exempt Private Activity Bonds
December 28, 2018
Daily Tax Update
New York Attorney General Announces Stipulation Dissolving Trump Foundation
December 18, 2018
Daily Tax Update
IRS, Treasury Issue Guidance on Previously Taxed Earnings and Profits
December 14, 2018