Elizabeth Stevens joined Caplin & Drysdale in 2015 as an Associate after her clerkship with Judge Robert A. Wherry, Jr., of the U.S. Tax Court. Ms. Stevens' combined experience in government, private practice, and the nonprofit sector gives her a 360-degree perspective on federal income tax and corporate issues, as well as valuable insights that benefit the firm's corporate and individual clients.
Services
Ms. Stevens' practice centers on international tax planning and advocacy for corporate clients. Matters involve transfer pricing, U.S. inbound investment taxation, and counseling on the tax implications of multinational groups' transactions and entity structures. Illustrations of Ms. Stevens' legal services include:
- advising corporate clients on transfer pricing planning, documentation, and compliance, including negotiating Advance Pricing Agreements;
- representing clients in LBO transactions and assisting with the drafting and negotiation of partnership and LLC operating agreements;
- guiding clients seeking Competent Authority assistance under bi-national Double Taxation Avoidance Agreements and counseling on other treaty-related matters, such as the creation and taxation of permanent establishments;
- evaluating and advising on the tax consequences of multinational enterprises’ restructuring proposals; and
- representing clients in tax litigation matters and providing strategic guidance in pre-litigation controversies.
Highlights
Previously, Ms. Stevens 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 graduated first in her class from California Western School of Law. Before earning her law degree, Ms. Stevens served as a naval cryptology officer deployed on the USS Nimitz in support of Operation Iraqi Freedom. She received her commission through the Navy's ROTC program after earning a degree in international political economy at Georgetown University.
Recent Speaking Engagements
- 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
- "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 Arielle M. Borsos, 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.