Tax Advisers - Deloitte

United States
Patricia Gimbel Lewis
Caplin & Drysdale
One Thomas Circle, NW
Washington, DC 20005
US
Tel: (1) 202 862 5017
Fax: (1) 202 429 3301
Email: pgl@capdale.com
Website: www.caplindrysdale.com
Patricia Gimbel Lewis is a member of Caplin & Drysdale, a 60-attorney law firm in
Washington DC that focuses on tax matters. Ms Lewis’ practice centres on international
transfer-pricing issues, competent authority matters, and other aspects of international
taxation, including 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 US subsidiaries of
large Japanese corporations, as well as affiliates of corporations in the UK, Sweden,
Germany, Israel, and other foreign countries.
Ms Lewis co-chaired the IRS/George Washington University Annual Institute on
International Taxation for 2000 and 2001 and serves on its advisory board. Recent articles
by Ms Lewis include:
• “Play It Again, Sam – The IRS (More or Less) Finishes the Section 482 Services
Regulations” The Tax Executive (October 2006);
• “The Law of Unintended Consequences: International Implications of Section 409A”
The Tax Executive (March/April 2005);
• “What’s New? What’s Missing? The IRS Updates APA Procedures” The Tax Executive
(July/August 2004);
• “Markers and Musings on the Proposed § 482 Services Regulations” The Tax Executive
(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 also presented speeches on these topics to many audiences (the ITR Annual
Transfer Pricing Forum, ABA Taxation Section, and Tax Executives Institute).
Ms Lewis received her law degree (JD cum laude) from Harvard Law School in 1971. In
the same year she also received an MBA, with high distinction, from the Harvard
University Graduate School of Business Administration, where she was a Baker Scholar.
Her undergraduate degree is from Wellesley College.
Ms Lewis is a fellow of the American College of Tax Counsel, the American Bar
Foundation, and the American College of Employee Benefits Counsel. She served on the
IRS Commissioner’s advisory group from 1994 through 1996. Ms Lewis co-chaired the
DC Bar Taxation Section from 1992 through 1995, and has been a regular participant in,
and co-drafter of, various projects of the ABA taxation section’s foreign committees on
matters such as the section 482 regulations, advance pricing agreements, competent
authority procedures, cost-sharing agreements and penalties.
280 Guide to the World’s Leading Tax Advisers