Elizabeth Stevens is a Member of the Firm and practices across the International Tax, Tax Controversies, and Business, Investment & Transactional Tax groups. Her client representations span international tax and transfer pricing planning and advocacy for multinational corporations and domestic and cross-border tax structuring, transactional, and compliance advice to high net-worth individuals and privately held businesses, including partnerships, LLCs, and S-corporations.
Services
Ms. Stevens’ experience in international tax matters bridges transfer pricing advisory work, primarily for U.S. multinationals, and international tax planning and structuring, primarily for foreign companies and non-U.S. persons investing or conducting business in the United States. In the transfer pricing space, Ms. Stevens advises corporate clients on planning, documentation, and compliance, with a particular focus on dispute resolution and prevention and tax certainty processes such as the Mutual Agreement Procedure (MAP) and Advance Pricing Agreements (APAs). Ms. Stevens also regularly advises on other treaty-related matters, such as the creation and taxation of permanent establishments, residency, and eligibility for treaty benefits.
For both cross-border and U.S.-based clients, Ms. Stevens provides deal representation in acquisitions, joint ventures, and buy-out transactions. Services include the drafting and negotiation of stock and asset purchase agreements, partnership and LLC operating agreements, employment agreements, and other key transaction documents. She also advises tax partnerships and S-corporations on federal income tax planning, structuring, and compliance matters.
In recent years, Ms. Stevens’ international tax practice has expanded to emphasize both federal income tax advice to individual taxpayers claiming bona fide residency in U.S. possessions such as Puerto Rico and the U.S. Virgin Islands and their businesses, and advice to employees and employers on the tax implications of remote and mobile work arrangements.
Highlights
Ms. Stevens began her professional life as a U.S. naval officer. After earning her law degree, she practiced for several years in civil litigation, estate planning, employment matters, and general business advisory and transactions. Her roles before joining Caplin & Drysdale included positions at a private law firm and a nonprofit organization and clerkships with then-Chief Judge Royce Lamberth of the U.S. District Court for the District of Columbia and Judge Robert A. Wherry, Jr. (Ret.) of the U.S. Tax Court.
Ms. Stevens discovered her calling as a tax lawyer at New York University School of Law, where she earned an LL.M. in Taxation, but continues to leverage her broader lawyering experience in serving as a trusted counselor for clients on their legal matters.
Admissions & Education
Bar & Court Admissions
- California
- District of Columbia
- U.S. Supreme Court
- U.S. Tax Court
Education
LL.M. in Taxation, New York University School of Law, 2014, Harry J. Rudick Memorial Award
J.D., California Western School of Law, 2008, summa cum laude
B.S. in Foreign Service, Georgetown University, 2002, magna cum laude
Recognitions & Noteworthy
Honors & Recognitions
- The Legal 500, Recommended 2020-Present
Professional Activities & Affiliations
Other Professional Affiliations
Council Director, American Bar Association, Section of Taxation
Member, U.S. Council for International Business
Member, Caplin & Drysdale’s Diversity, Equity & Inclusion Committee
Former Chair, American Bar Association, Section of Taxation, Transfer Pricing Committee
