Elizabeth Stevens is a Member of the Firm and practices in the International Tax, Tax Controversies, and Business, Investment & Transactional Tax groups.
Services
Ms. Stevens' practice centers on international tax planning and advocacy for corporate clients. Matters primarily involve transfer pricing and U.S. outbound and inbound investment planning and structuring.
Illustrations of Ms. Stevens' legal services include:
- advising corporate clients on transfer pricing planning, documentation, and compliance, including negotiating Advance Pricing Agreements;
- counseling clients on the implications of the 2017 U.S. tax reform for particular business lines and models and on alternatives for mitigating resulting risk and uncertainty;
- guiding clients seeking Competent Authority assistance under bilateral income tax treaties and advising on other treaty-related matters, such as the creation and taxation of permanent establishments and eligibility for treaty benefits;
- evaluating and advising on the tax consequences of multinational enterprises’ restructuring proposals;
- representing clients in LBO transactions and assisting with the drafting and negotiation of partnership and LLC operating agreements; and
- representing clients in tax litigation matters and providing strategic guidance in pre-litigation controversies.
Highlights
Previously, Ms. Stevens served as a judicial clerk to Judge Robert A. Wherry, Jr. (Ret.) of the U.S. Tax Court and practiced at a regional law firm in California, where she assisted corporate and individual clients with business transactions, estate planning, employment matters, and civil litigation. Ms. Stevens has also practiced as a litigation fellow at Americans United for Separation of Church and State in Washington, D.C., where she represented plaintiffs in federal court lawsuits involving free speech and religious discrimination claims. Prior to her fellowship, Ms. Stevens served as a law clerk to then-Chief Judge Royce Lamberth of the U.S. District Court for the District of Columbia.
Ms. Stevens earned an LL.M. in Taxation from New York University School of Law and graduated first in her class from California Western School of Law. Before earning her law degree, Ms. Stevens served as a U.S. naval officer. She received her commission through the Navy's ROTC program and holds a degree in international political economy from Georgetown University.
Recent News
- 17 Caplin & Drysdale Attorneys Recognized in 2020 Legal 500 Ranking, The Legal 500, July 6, 2020
- Elizabeth Stevens Weighs in on BEPS and OECD, Tax Notes, May 11, 2020
- Law360 Quotes Elizabeth Stevens on Governments Questioning Losses, Law360, May 1, 2020
- Elizabeth Stevens Comments on GILTI and Virus Losses in Law360, Law360, April 29, 2020
- Elizabeth Stevens Talks to Law360 on OECD Tax Proposals, Law360 Tax Authority, October 1, 2019
- Caplin & Drysdale Announces the Election of Four New Members, October 1, 2019
- Law360 Quotes Elizabeth Stevens on GILTI, Law360, July 10, 2019
- Elizabeth Stevens Talks to Bloomberg Law on MAP, Bloomberg Law, June 4, 2019
- Elizabeth Stevens Comments on U.S. & India APAs, Law360 Tax Authority, May 10, 2019
- Law360 Quotes Elizabeth Stevens: Defining Marketing, Trademark IP Could Sink OECD Tax Plan, Law360 Tax Authority, April 29, 2019
- Elizabeth Stevens Comments: U.S. Seeks to Broaden Digital Tax Discussions, Law360 Tax Authority, March 8, 2019
- Caplin & Drysdale Honors the Women of the Firm, Caplin & Drysdale, March 8, 2019
- 5 Caplin & Drysdale Attorneys Contribute to FBA 2019 Tax Law Conference, Caplin & Drysdale, March 6, 2019
- Law360 Quotes Elizabeth Stevens: Lack of Noncash Exceptions in BEAT Rules Has Wide Scope, Law360, December 18, 2018
- David Rosenbloom and Elizabeth Stevens Submit Amicus Brief to Uphold Decision Favoring Amazon in IRS Transfer Pricing Dispute, Law360, July 9, 2018
- Law360 Quotes Elizabeth Stevens on BEAT Policies to Look Out For Later This Year, Law360, July 5, 2018
- U.S. News Quotes Elizabeth Stevens on How Changes to BEAT Could Impact Cost of Goods Sold, U.S. News & World Report, May 25, 2018
- 9 Caplin & Drysdale Attorneys Contribute to ABA's Annual Section of Taxation Meeting, Caplin & Drysdale, May 9, 2018
- Elizabeth Stevens Discusses Further Clarification on BEAT Rule with Bloomberg, Bloomberg BNA, April 16, 2018
- Law360 Speaks to Elizabeth Stevens About Retiring Tax Court Judge Robert Wherry, Law360, January 5, 2018
- Law360 Talks to Clark Armitage, Peter Barnes, and Elizabeth Stevens on International Tax Cases to Watch in 2018, Law360, January 2, 2018
- Caplin & Drysdale Honors All Who Served in Our Nation's Military, Caplin & Drysdale, November 11, 2016
- Elizabeth Stevens Speaks with Army Wife Talk Radio on Employer Tax Breaks for Hiring Vets, Army Wife Talk Radio, April 5, 2016
- Caplin & Drysdale Creates New Version of Tax Guide to Help Employers Hire Veterans, Caplin & Drysdale, March 7, 2016
Click here for a full list of media coverage.
Speaking Engagements
- Moderator, Global Transfer Pricing Developments, International Tax Review, Women in Tax Forum Europe 2020, September 17, 2020
- Moderator, TP & the U.S. Tax Landscape, TP Minds International, September 3, 2020
- Presenter, Keeping Your International Tax Structure Healthy During a Pandemic, NERA Economic Consulting, July 29, 2020
- Panelist, TP Debate (Economists vs Lawyers), National Association for Business Economics, 10th Annual NABE Transfer Pricing Symposium, July 22, 2020
- Panelist, Tax Treaties and Dispute Resolution, Practicing Law Institute, Basics of International Taxation 2020, July 22, 2020
- Panelist, Transfer Pricing Concerns, International Tax Review, Leading Women in Tax Forum, March 3, 2020
- Speaker, Transfer Pricing Basics After Tax Reform, TEI Houston 2020 Tax School, February 25, 2020
- Moderator, Finding Foreign Derived Intangible Income Under the Proposed Regulations, AICPA & CIMA U.S. Tax Update Conference, September 23, 2019
- Moderator, Structuring to Address the Base Erosion and Anti-Abuse Tax, AICPA & CIMA U.S. Tax Update Conference, September 23, 2019
- Panelist, The Great TP Debate, National Association for Business Economics, 9th Annual NABE Transfer Pricing Symposium, July 16, 2019
- Panelist, Improving Tax Certainty (Part II) - MAP, OECD International Tax Conference, June 4, 2019
- Moderator, Transfer Pricing and The U.S. Tax Landscape - One Year After Tax Cuts and Jobs Act, TP Minds International 2019, March 19, 2019
- Moderator, Eyes on the Horizon: What Will Follow the TCJA?, Federal Bar Association, 43rd Annual Tax Law Conference, March 8, 2019
- Chair, International Symposium, Federal Bar Association, 43rd Annual Tax Law Conference, March 7, 2019
- Panelist, Alternatives to Resolving Large, Complicated, Corporate Tax Disputes, Leading Women In Tax Forum 2019, February 26, 2019
- Panelist, Recent International Tax Developments Under TCJA – Section 965, GILTI and BEAT, Committee of Banking Institutions on Taxation (CBIT), 49th Annual Fall Tax Day, October 25, 2018
- Speaker, Overview of U.S. Tax Reform, AICPA & CIMA U.S. Tax Reform Conference, September 17, 2018
- Chair, Tax Incentives to Attract Foreign Direct Investments Without Eroding the Tax Base, 2018 International Fiscal Association Congress, September 5, 2018
- Speaker, Part 4 of 4 New Tax Practitioners Lunch Series, D.C. Bar, May 30, 2018
- Panelist, Amending LLC and Partnership Agreements to Address Tax Reform and the New IRS Audit Rules, Strafford Publications, May 16, 2018
- Panelist, A Renewed Focus on CoGS, 2018 ABA Section of Taxation May Meeting, May 10, 2018
- Moderator, Centralized Partnership Audit Regime Update, Part 2, D.C. Bar, April 4, 2018
- Moderator, Impact of the U.S. Tax Reform on Transfer Pricing Planning, TP Minds International, March 20, 2018
- Panelist, To the Shores of Tripoli: A Military Tax Overview, American Bar Association Section of Taxation 2018 Midyear Meeting, February 9, 2018
- Panelist, TP Challenge: Analysis of EU State Aid Decision for Apple, National Association for Business Economics, 7th Annual NABE Transfer Pricing Symposium, July 19, 2017
- Panelist, Competent Authorities – Live Negotiation Simulations Involving Canada, China, and US, University of San Diego School of Law, 5th Annual USD Transfer Pricing Symposium, April 27, 2017
- Panelist, The Foreign Tax Credit, ABA Tax Section, January 20, 2017
- Moderator, Transfer Pricing Litigation Through the Lens of Medtronic, ABA Tax Section, January 19, 2017
Click here for a full list of speaking engagements.
Recent Publications
- "TAX PRACTICE: A Silver Linings Guidebook: Corporate Planning for Coronavirus Losses,"
with J. Clark Armitage and Josiah Child, Tax Notes Federal, May 18, 2020
- "CARES Act Offers Income Tax Relief for Business,"
with J. Clark Armitage, Jonathan S. Brenner, Kirsten Burmester, and H. David Rosenbloom, Caplin & Drysdale Client Alert, March 27, 2020
- "The OECD Unified Approach Marches (Stumbles?) Forward,"
with J. Clark Armitage, Caplin & Drysdale Client Alert, February 11, 2020
- "Updated Partnership Reporting Requirements for 2019,"
with Jonathan S. Brenner, Caplin & Drysdale Client Alert, December 13, 2019
- "OECD Announces a Public Consultation for Global Minimum Tax Rules,"
with H. David Rosenbloom, J. Clark Armitage, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 25, 2019
- "An OECD "Unified Approach" to Addressing the Challenges of the Digital Economy,"
with H. David Rosenbloom, J. Clark Armitage, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 4, 2019
- "The Proposed GILTI High Tax Exclusion,"
with Jonathan S. Brenner and Amanda M. Leon, Caplin & Drysdale Client Alert, July 1, 2019
- "INSIGHT: BEAT Strikes the Wrong Note,"
with Peter A. Barnes, Bloomberg Tax: Daily Tax Report, March 16, 2018
- "GILTI Pleasures,"
with H. David Rosenbloom, Tax Notes International Magazine, February 12, 2018
- "New Partnership Audit Rules Go Live,"
with Jonathan S. Brenner, Caplin & Drysdale Client Alert, January 9, 2018
- "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets,"
with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 6, 2017
- "Different Viewpoint Not a Misrepresentation: Tax Court Holds IRS Abused Its Discretion in Cancelling Eaton's APAs,"
with Patricia Gimbel Lewis and J. Clark Armitage, Caplin & Drysdale Client Alert, August 24, 2017
- "Congress Looks to Fix New Partnership Audit Rules,"
with Charles M. Ruchelman, Jonathan S. Brenner, and Rachel L. Partain, International Law Office, January 6, 2017
- "Congress Looks to Fix New Partnership Audit Rules,"
with Charles M. Ruchelman, Jonathan S. Brenner, and Rachel L. Partain, Caplin & Drysdale Client Alert, December 14, 2016
- "New Regulations Change Allocation of Partnership Liabilities,"
with Jonathan S. Brenner, International Law Office, November 4, 2016
- "New Regulations Change Allocation of Partnership Liabilities,"
with Jonathan S. Brenner, Global Tax Weekly, November 3, 2016
- "New Regulations Change Allocation of Partnership Liabilities,"
with Jonathan S. Brenner, Caplin & Drysdale Client Alert, October 24, 2016
- "2016 Federal Tax Benefits for Hiring Qualified Veterans, National Guard Members and Reservists" (Book),
with Beth Shapiro Kaufman, Caplin & Drysdale, Chartered, March 1, 2016
- "Transfer Pricing Audits: Flipping the Tested Party,"
with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Neal M. Kochman, Wolters Kluwer, August 27, 2015
- "Transfer Pricing Audits: Flipping the Tested Party,"
with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Neal M. Kochman, Caplin & Drysdale Client Alert, August 13, 2015
- "IRS Releases Guidelines for Examining CFC Transactions,"
with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Neal M. Kochman, Caplin & Drysdale Client Alert, July 29, 2015
- "OECD's Proposed New Approach to Transfer Pricing of Intangibles: A Critique,"
New York University, June 29, 2014
- "Crawford's Last Stand? What Melendez-Diaz v. Massachusetts Means for the Confrontation Clause and for Criminal Trials,"
2 AKRON J. CONST. L. & POL'Y 81, June 2, 2011
- "COMMENT: Deputy-Doctors: The Medical Treatment Exception after Davis v. Washington,"
43 CAL. W. L. REV. 451, 2007, May 1, 2007
Click here for a full list of publications.