Patricia Gimbel Lewis is a member in Caplin & Drysdale's Washington, D.C. office, having started with the firm in 1971. Ms. Lewis’ practice currently 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. In this context, she has represented U.S. subsidiaries of major Japanese corporations, as well as affiliates of corporations in the United Kingdom, Sweden, Germany, and other foreign countries. Ms. Lewis was particularly active in the fight to protect the confidentiality of APAs from unwarranted disclosure. In the Expert Guides issued by Legal Media Group, she has been selected in “Best of the Best” for Transfer Pricing and the “World’s Leading Transfer Pricing Advisers.” Chambers USA lists Ms. Lewis as a “leading individual” for tax in the District of Columbia.
Ms. Lewis was Co-Chair of the IRS/George Washington University Annual Institute on International Taxation for 2000 and 2001 and continues on its Advisory Board. Recent published articles by Ms. Lewis include:
Coming Full Circle? Secondary Adjustments and Repatriation in Transfer Pricing Cases, TAX MANAGEMENT TRANSFER PRICING REPORT (BNA) (May 8, 2008);
Play it Again Sam – The IRS (More or Less) Finishes the Section 482 Services Regulations, THE TAX EXECUTIVE (September/October 2006);
What’s New? What’s Missing? The IRS Updates APA Procedures, THE TAX EXECUTIVE (July/August 2004);
Markers and Musings: The Proposed Section 482 Service Regulations, THE TAX EXECUTIVE (November/December 2003);
The Final Word on Stock Options in Cost Sharing Arrangements??, TAX MANAGEMENT INTERNATIONAL JOURNAL (December 2003);
Option Wars: Upping the Ante for Cost Sharing Arrangements, TAX MANAGEMENT INTERNATIONAL JOURNAL (November 2002);
Second First? Transfer Pricing in Secondment of Personnel, THE TAX EXECUTIVE (July/August 2002);
Cost Sharing Arrangements Come of Age, BNA TAX MANAGEMENT MEMORANDUM (2000);
Mining for Nuggets in the IRS APA Report, THE TAX EXECUTIVE (May/June 2000);
Now What? Collateral Consequences of Transfer Pricing Adjustments, THE TAX EXECUTIVE (1995); and
Strategic Choices for Transfer-Pricing Controversies, THE TAX EXECUTIVE (1992). She has presented speeches to the ABA Taxation Section, IRS, European-American Business Council, Tax Executives Institute, World Trade Institute, and International Fiscal Association, and was a regular columnist for the CCH JOURNAL OF GLOBAL TRANSFER PRICING.
Ms. Lewis is a fellow of the American College of Tax Counsel. She was honored to serve on the IRS Commissioner’s Advisory Group from 1994 through 1996. Ms. Lewis has been active in the D.C. Bar Taxation Section, including serving as co-chair of the Steering Committee from 1992 through 1995. She is active in the ABA Taxation Section’s foreign and transfer pricing committees.