Elizabeth Stevens

Member at CAPLIN & DRYSDALE

Speaker

Elizabeth Stevens is a Member of the Firm and practices across the International Tax, Tax Controversies, and Business, Investment & Transactional Tax groups. Her practice spans international tax planning and advocacy for multinational corporations, as well as advising clients on federal income tax structuring and transactional representation for partnerships, LLCs, and S-corporations. Ms. Stevens’ experience in international tax matters primarily involves transfer pricing and U.S. outbound and inbound investment planning and structuring. In the transfer pricing space, she advises corporate clients on planning, documentation, and compliance, with a particular focus on negotiating Advance Pricing Agreements (APAs). Ms. Stevens regularly represents clients seeking Competent Authority assistance under bilateral income tax treaties and also advises on other treaty-related matters, such as the creation and taxation of permanent establishments and eligibility for treaty benefits. For both cross-border and U.S.-based clients, Ms. Stevens provides representation in acquisitions and buy-out transactions, including the drafting and negotiation of partnership and LLC operating agreements. She also advises partnerships and S-corporations on federal income tax planning, structuring, and compliance matters. In recent years, Ms. Stevens’ international tax practice has emphasized advice regarding the implications of recent and proposed U.S. and global tax reform initiatives for particular business lines and models and on alternatives for mitigating resulting risk and uncertainty. She also counsels multinational enterprises on the federal income tax consequences of restructuring proposals and provides strategic guidance in transfer pricing and other federal income tax controversy matters.