Patricia Gimbel Lewis

Patricia Gimbel Lewis is a member in Caplin & Drysdale's Washington, D.C. office, having started with the firm in 1971.

Services

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.

Highlights

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

• Co-Chair, Steering Committee, D.C. Bar Taxation Section, 1992-1995
• Member, IRS Commissioner's Advisory Group, 1994 -1996
• Speaker at conferences for the following groups, among others: ABA Taxation Section, IRS, Tax Executives Institute, IRS/GWU International Tax Institute, World Trade Institute, and International Fiscal Association

Awards & Honors

• Ranked as a leading lawyer in International Tax in the 2011-2012 editions of The Legal 500 
• Ranked as a Top Lawyer in the 2008-2013 editions of Chambers USA: 2011-2013 – Band 3 in Tax - District of Columbia  
• Selected in Legal Media Group's Guide to the World's Leading Lawyers - Best of the Best, as well as in their Guide to the World's Leading Tax Advisers, Transfer Pricing Advisers, and Women in Business
• Winner of the 2012 "Best in Transfer Pricing" award for Euromoney Legal Media Group's Women In Business Law Awards for the Americas region
• Recommended by PLC Which Lawyer? in international tax and AV rated by Martindale-Hubbell
• Listed in The Best Lawyers in America in the specialties of Employee Benefits Law and Tax Law from 2003-2013
• Ranked as a "Super Lawyer" by DC's Super Lawyers magazine from 2007-2013

Recent Publications

• Safe At Last? Transfer Pricing Safe Harbors on the Horizon,  Tax Management Transfer Pricing Report (Bloomberg BNA) (September 2012)
• What You Really Need to Know About Transfer Pricing, The Metropolitan Corporate Counsel (July/August 2012)
• Short Cuts for Small Fry: Why the IRS Should Reconsider Transfer Pricing Safe Harbors for Small Taxpayers, Transactions, Tax Management  Transfer Pricing Report (Bloomberg BNA) (April 2011)
• Survival Techniques: Transfer Pricing in a Sick Economy, The Tax Executive (May-June 2009)
• Coming Full Circle? Secondary Adjustments and Repatriation in Transfer Pricing Cases, Tax Management Transfer Pricing Report (Bloomberg BNA) (May 2008)
• Play it Again Sam – The IRS (More or Less) Finishes the Section 482 Services Regulations, The Tax Executive (September/October 2006)
• The Law of Unintended Consequences: International Implications of Section 409A, The Tax Executive (March/April 2005)
• The Final Word on Stock Options in Cost Sharing Arrangements??, Tax Management International Journal (December 2003)
• Second First? Transfer Pricing in Secondment of Personnel, The Tax Executive (July/August 2002)