After more than 22 years as Senior International Tax Counsel for General Electric Co. ("GE"), Peter Barnes joined Caplin & Drysdale as Of Counsel to the firm's International Tax Group in 2013.  His over 30 years of experience in the international tax arena help Mr. Barnes bring a wealth of knowledge to the firm and its clients.

Mr. Barnes served as president of the International Fiscal Association ("IFA") from November 2021 to November 2023. He serves as a Senior Fellow at the Duke Center for International Development ("DCID") at Duke University.  There, Mr. Barnes teaches in Duke's International Tax Program, which is jointly directed by DCID and Duke Law School.  At Duke, he also directs an annual week-long transfer pricing workshop for government tax officials and private sector advisors, many from developing countries. In 2015, Mr. Barnes was elected as the U.S. delegate to the Permanent Scientific Committee of the IFA.  In this role, he served a six-year term helping supervise the planning and implementation of the scientific work of IFA.

Services

Mr. Barnes' practice focuses on assisting multinational corporations in their global tax planning programs, including matters relating to transfer pricing, trademark licensing, and dispute resolution.  His tenure at GE, combined with his government experience, enabled Mr. Barnes to offer corporate clients a global strategic approach to their most complex issues.  Notable matters include: 

  • advice on transfer pricing issues for a privately held company worth more than$1 billion and undergoing its first major IRS audit;
  • secure a letter ruling from the Inland Revenue Authority of Singapore for a U.S.-based multinational; and
  • counsel a U.S.-based multinational on global tax issues with consequences in India, Singapore, and other jurisdictions.

Highlights

At GE, Mr. Barnes played a key role in supporting the company's international tax operations, with a particular emphasis on Asia.   From 1994 to 1997, he was based in Hong Kong.  Mr. Barnes helped build and lead GE's tax team across Asia, including extensive work in India, China, Japan, and Korea.  He led and assisted global programs for GE, including the company's trademark licensing and transfer pricing work.

Prior to joining GE, Mr. Barnes served as U.S. Deputy International Tax Counsel at the U.S. Treasury Department's Office of Tax Policy, where he represented the U.S. government in treaty negotiations and as a delegate to the Organization for Economic Co-operation and Development.  During his career at the U.S. Treasury, Mr. Barnes helped implement guidance arising from the Tax Reform Act of 1986.

From 2011 to 2013, Mr. Barnes was an Adjunct Professor at New York University School of Law Graduate Tax Program, teaching a course on "Asia-Pacific Tax Systems."

An avid lecturer, Mr. Barnes has conducted over 200 presentations, individually and as part of a panel, for tax conferences and internal General Electric training programs.  Recurring presentations include Harvard Law School and International Tax Program, multiple presentations (1992-present), Tax Executives Institute (Asia training programs), and IRS-GWU International Tax Conference (almost annually, since 1988).

Admissions and Education

Bar & Court Admissions
  • District of Columbia
  • U.S. Tax Court
Education

J.D., Yale Law School, 1980, Managing Editor, Yale Law Journal

Recognitions & Noteworthy

Honors & Recognitions

The Legal 500, Recommended, 2014-2016, 2018

The Legal 500, International Tax Team of the Year, 2014-2015

Best Lawyers in America, 2021-Present

Government Service

Deputy International Tax Counsel, U.S. Treasury, Office of International Tax Counsel, Treasury Service, 1986-1991

Law Clerk, Honorable Gerhard A. Gesell, U.S. District Court for the District of Columbia, 1980-1981

Professional Activities & Affiliations

Professional Activities
  • Senior Fellow, Duke Center for International Development  at Duke University
  • Member, IRS-GWU International Tax Conference Planning Committee
  • Panelist, OECD 50th Anniversary of Model Tax Convention (2008)
  • Member, USA Chapter, International Fiscal Association
  • Selector, Luce Scholars Program, Henry Luce Foundation
  •  President, International Fiscal Association, 2021-Present
  • U.S. Delegate, Permanent Scientific Committee, International Fiscal Association, 2015-2021

Newsroom & Publications

News
Speaking Engagements

An avid lecturer, Mr. Barnes has conducted over 200 presentations, individually and as part of a panel, for tax conferences and internal General Electric training programs.  Recurring presentations include Harvard Law School and International Tax Program, multiple presentations (1992-present), Tax Executives Institute (Asia training programs), and IRS-GWU International Tax Conference (almost annually, since 1988).  Below are recent presentations:

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