Patricia Gimbel Lewis
Caplin & Drysdale
Patricia Gimbel Lewis Senior Counsel

P: (202) 862-5017

F: (202) 429-3301

Washington, D.C. Office


Ms. Lewis' practice focuses on international transfer pricing issues, competent authority matters, and other aspects of international taxation. This includes tax planning advice on compliance with U.S. and foreign transfer pricing rules in connection with ongoing business operations or business transactions, as well as assistance in the event of tax audits and other administrative controversies. A particular emphasis is the negotiation of advance pricing agreements (APAs) between taxpayers, the IRS, and foreign tax authorities.





Ms. Lewis represents businesses in many industries, including financial services. She has worked with major U.S.-based multinationals as well as U.S. affiliates of foreign corporations, involving cross-border transactions with Japan, the United Kingdom, France, India, Canada, Brazil, Sweden and Germany, among others. Ms. Lewis was particularly active in the fight to protect the confidentiality of APAs from unwarranted disclosure.

Professional Activities

  • Member, United States Council for International Business (USCIB), 2013-Present
  • Co-Chair, Steering Committee, D.C. Bar Taxation Section, 1992-1995
  • Member, IRS Commissioner's Advisory Group, 1994-1996

Practice Area(s)

Awards & Rankings

  • Chambers USA, 2008-Present
  • The Legal 500, Leading Lawyer, 2011-2013; Recommended, 2014-Present
  • The Legal 500, International Tax Team of the Year, 2014-2015
  • Best Lawyers in America, Women in the Law, International Tax and Employee Benefits, 2016; Listed 2003-Present
  • Super Lawyers, Top 50 Women, 2008-2012, Washington, D.C. 2008-Present
  • Fortune Magazine, Women Leaders in the Law, 2014
  • Expert Guides' The Best of the Best, Transfer Pricing, 2014-Present
  • Expert Guides' World's Leading Women in Business Law, Transfer Pricing, 2010-Present
  • Expert Guides' World's Leading Tax Advisers, 2008, 2014-Present
  • Expert Guides' World's Leading Transfer Pricing Advisers, 2003-Present
  • The Washingtonian, Top Lawyer, 2017-Present
  • Lexology, Client Choice, Corporate Tax, Washington, D.C., 2019
  • World Tax, Tax Controversy Leaders, 2019 - Present
  • Martindale-Hubbell® AV® Preeminent™
  • World Tax, Women in Tax Leaders, 2019 - Present

Recent News

Click here for a full list of media coverage.

Recent Speaking Engagements

Ms. Lewis regularly speaks before large groups on topics relating to international tax and transfer pricing.  Groups include the ABA Taxation Section, IRS, Tax Executives Institute, IRS/GWU International Tax Institute, and International Fiscal Association.  Below is a list of Ms. Lewis' recent speaking engagements.

  • Panelist, (1) Recent Developments of Transfer Pricing Regimes and Practices and (2) How to Cope with Global Transfer Pricing Challenges, Yulchon LLC / Korea International Trade Association (KITA), November 2, 2017
  • Panelist, Recent U.S. Transfer Pricing Litigation and What It Means, National Association for Business Economics, 7th Annual NABE Transfer Pricing Symposium, July 19, 2017
  • Panelist, ABA-APMA Roundtable, 2017 ABA Section of Taxation May Meeting, May 13, 2017
  • Moderator, The Great TP Debate, National Association for Business Economics, 6th Annual NABE Transfer Pricing Symposium, July 19, 2016
  • Panelist, BEPS Core Concepts and Themes, Bloomberg BNA, Global Transfer Pricing Conference - Washington, D.C., June 12, 2015
  • Transfer Pricing Update: Discussion of Recent Issues and Guidance on Transfer Pricing, American Petroleum Institute, 81st Annual Federal Tax Forum, April 28, 2015
  • Moderator, Treaties: BEPS-Driven Conceptual Changes and Dispute Resolution Needs, USA Branch of the International Fiscal Association, 2015 Annual Conference, February 26, 2015
  • Moderator, Advance Pricing Agreement and Competent Authority Update, American Bar Association, 2014 Joint Fall CLE Meeting, September 19, 2014
  • Speaker, Risks in a TP Context: What are They, What Does it Mean to Move Them? Expected Returns?, 4th Annual Transfer Pricing Symposium, National Association for Business Economics (NABE), July 23, 2014
  • Moderator, Using APAs and MAP to Mitigate Risk and Disputes, TP Minds Americas Transfer Pricing Summit 2014, February 18, 2014
  • Chair, The New APMA Revenue Procedures, District of Columbia Bar Association, February 12, 2014
  • Speaker, Transfer Pricing, The George Washington University Law School 27th Annual Institute on Current Tax Issues in International Taxation, December 12, 2013
  • Chair, A Practical Guide to Transfer Pricing: International Developments and the U.S. Response, Federal Bar Association, 37th Annual Tax Law Conference, March 1, 2013
  • Chair, Safe Harbor Challenge, National Association for Business Economics (NABE), July 31, 2012
  • Speaker, Roundtable Discussion with IRS National Director of Transfer Pricing Operations, International Fiscal Association (IFA), July 25, 2012
  • Panelist, OECD's Work on Transfer Pricing and Administration, OECD International Tax Conference, June 4, 2012
  • Chair, Striving for Efficiencies in Transfer Pricing Enforcement and Compliance, The George Washington University Law School, 24th Annual Institute on Current Issues in International Taxation, December 15, 2011
  • Speaker, APAs – An Alternative to the Traditional Examination Process, Pharmaceutical & Medical Device Tax Management & Transfer Pricing Conference, June 21, 2010
  • Speaker, Korea-U.S. Advance Pricing Agreements: A "Time-Tested" Approach, for New or Uncertain Times, Yulchon LLC, October 15, 2009

Click here for a full list of speaking engagements.

Recent Publications

Click here for a full list of publications.


  • J.D., Harvard Law School, 1971, cum laude
  • M.B.A., Harvard University, 1971, with high distinction; Baker Scholar
  • B.A., Wellesley College, 1966, Durant Scholar

Bar and Court Admissions

  • District of Columbia
  • New York
  • Massachusetts
  • U.S. Tax Court
  • U.S. Claims Court
  • U.S. Court of Appeals, District of Columbia Circuit
  • U.S. District Court, District of Columbia
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