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Tax Advisers - Deloitte

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United States<br />

Marc M Levey<br />

Baker & McKenzie LLP<br />

805 Third Avenue<br />

New York, NY 10022<br />

US<br />

Tel: (1) 212 891 3944<br />

Fax: (1) 212 310 1644<br />

Email: marc.m.levey@bakernet.com<br />

Website: www.bakernet.com<br />

Marc Levey is a partner in the New York office of Baker & McKenzie. He has over 25<br />

years of experience in international taxation and is a nationally recognized expert in his<br />

field, particularly in structuring and defending transfer-pricing strategies. He has<br />

frequently been acknowledged by Legal Media Group as one of the world’s leading tax<br />

advisors, and was included in the Best of the Best, global tax experts. Mr Levey has also been<br />

recognized in the Best Lawyers in America and in New York Magazine as among “The New<br />

York Area’s Best Lawyers.”<br />

His practice focuses on transfer pricing and cross-border transactions and mergers and<br />

acquisitions; tax controversies and litigation; and general corporate, international and<br />

partnership taxation, and multinational restructurings. Mr Levey previously served as a<br />

tax attorney with the International <strong>Tax</strong> Ruling Group of the National Office of the IRS<br />

from 1975 to 1977. He acted as senior trial attorney with the <strong>Tax</strong> Division of the US<br />

Department of Justice from 1977 to 1981, was the special attorney to the Attorney-<br />

General of the US Department of Justice in 1982, and was formerly a partner in a bigfive<br />

firm, where he headed the transfer-pricing practice for the greater metropolitan New<br />

York area and was member of the firm’s international task force. In addition, he was a tax<br />

partner at a prominent New York-based law firm.<br />

Mr Levey represents a wide range of clients in proceedings before the IRS and federal<br />

courts and has substantial experience in handling tax controversies. He has been, and is,<br />

tax counsel on numerous high-profile tax court cases, including Club Med Sales Inc v<br />

Commissioner; Astra USA Inc v Commissioner; Saint Gobain Corporation et al v Commissioner;<br />

Frette SA v Commissioner; Andres Courrage Inc v Commissioner; Framatome Connectors USA<br />

v Commissioner; and El Paso Maquila Sales Inc v Commissioner. He has also successfully<br />

negotiated conclusions to numerous IRS tax audits, appeals controversies, fast-track<br />

appeals, competent authority matters and advance-pricing agreements.<br />

He has been a featured speaker at numerous international tax seminars throughout the<br />

world, such as <strong>Tax</strong> Executive Institute, Practicing Law Institute, International Fiscal<br />

Association, International <strong>Tax</strong> Review, Canadian <strong>Tax</strong> Foundation, College Colegio de<br />

Contadores de Pubicio Mexico, Counsel for <strong>Tax</strong> Education, American Bar Association,<br />

and NYU <strong>Tax</strong> Institute. He is also the editor and author of the tax treatise US <strong>Tax</strong>ation of<br />

Foreign Controlled Business, co-author of International Transfer Pricing OECD Guidelines,<br />

Warren Gorman Lamont treatises, the co-author of Transfer Pricing: Rules, Compliance and<br />

Controversy, CCH Incorporated, and the co-author of “Transfer Pricing: Alternate<br />

Practical Strategies” 890 <strong>Tax</strong> Management Foreign Income Portfolios (2001). Mr Levey has<br />

also authored over 100 publications over the last 10 years in leading global tax publications.<br />

Mr Levey is founding chairman of the American Bar Association’s <strong>Tax</strong> Section, Transfer<br />

Pricing Committee, and prior vice chairman of the Affiliated and Related <strong>Tax</strong> Party<br />

Committee, director of International <strong>Tax</strong> Institute Inc, and member of the advisory board<br />

of numerous leading tax journals such as Journal of International <strong>Tax</strong>ation, International <strong>Tax</strong><br />

Journal and BNA Foreign <strong>Tax</strong> Portfolio.<br />

Mr Levey is a graduate of Wilkes University (BS economics and accounting, 1969),<br />

University of Cincinnati College of Law (JD 1972) and the University of Miami Law<br />

School (LLM taxation, with honours, 1973). He is a member of the New York, California,<br />

District of Columbia, Pennsylvania and Illinois Bar Associations and the American Bar<br />

Association.<br />

279

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