Patricia Anne Rexford has joined Baker & McKenzie as a tax controversy and litigation partner, further strengthening the Firm’s Tax Practice Group with 18 years of experience representing taxpayers at all stages of tax controversies.
Repeatedly recognized in Legal 500 as among the top tax controversy lawyers in the United States, Ms. Rexford has represented clients in a wide range of complex tax controversy matters, including audit, IRS administrative appeals, trial and appellate court review and matters before the US Supreme Court. Over the course of her career, she has handled matters involving: section 482 transfer pricing and cost sharing issues; DISC, FSC, and ETI issues; section 199 issues; tonnage tax issues; Subpart F and section 956 issues (foreign base company sales and services income, shipping income, obligations of a US person, and “banking exception”); substance-over-form issues; tax-free reorganizations; section 752 allocation of basis for partnership indebtedness; foreign tax credits; foreign-source income on export sales; proper treatment of construction allowances; deductibility of stock options; deductibility of transaction-related investment-bank fees; summons enforcement; and penalties. Ms. Rexford has also served as a liaison and facilitator between US and Mexican legal teams with respect to Mexican tax audits.
“The extensive capabilities of Baker & McKenzie’s Tax Practice are well known, and the Firm’s impressive global platform is a great fit for my practice,” said Ms. Rexford. “I’m delighted to join Baker & McKenzie.”
Some of Ms. Rexford’s significant matters include:
• Various Fast Track and Appeals representations, including transfer pricing, cost sharing, subpart F, FSC, ETI, "busted 351," section 956 indebtedness, section 752 partnership basis allocation, tonnage tax, stock option deductibility, and penalty issues.
• The Tribune Co. v. Commissioner, 125 T.C. 110 (2005); holding that the divestiture of Matthew Bender was a taxable sale and not a tax-free reorganization; settled pending appeal in the Seventh Circuit.
• The Limited, Inc. v. Commissioner, 286 F.3d 324 (6th Cir. 2002), rev’g, 113 T.C. 169 (1999); holding that a CFC’s purchase of CDs from an affiliated credit card bank qualified as §956(c)(2)(A) “deposits with persons carrying on the banking business.”
“Tricia is a unique, five-star talent who is the perfect addition to our tax controversy practice, at a time when almost every major public company faces significant tax controversy,” said Len Terr, chair of the North American Tax Practice Group. “She is a proven winner, problem-solver and strategist who finds ways for companies to succeed whether through litigation or alternative mechanisms.”
Ms. Rexford is the latest in a series of prominent hires for the practice. Mary Bennett, the former head of the Tax Treaty, Transfer Pricing & Financial Transactions Division of the Organisation for Economic Cooperation and Development’s Centre for Tax Policy & Administration (CTPA), recently returned to the Firm as a partner based in the Firm’s Washington, DC office, and Caroline Silberztein, head of the CTPA’s Transfer Pricing Unit, also recently joined as a partner based in the Paris office. The practice also recently welcomed Partner Joshua Odintz to its Washington, DC office, Juliana Cangussu Dantas to its Amsterdam offices, and Partner Jacques Bernier to the Toronto office.
“Tricia is an excellent tax controversy litigator who is well regarded in her field, and we are thrilled to have her join Baker & McKenzie,” said Michael L. Morkin, Managing Partner of the Firm’s Chicago Office. “She joins a Chambers-ranked Tax Practice that is growing within the region and globally, and her nearly two decades of experience in tax matters will be an invaluable resource for our clients.”
About Patricia Anne Rexford
Ms. Rexford graduated with honors from University of Chicago Law School in 1993, and is a member of the Order of the Coif. She was Comment Editor of the University of Chicago Law School Roundtable. She graduated cum laude from Harvard College in 1989, was on the Dean’s List and received the John Harvard Scholarship.
Prior to joining Baker & McKenzie, she was a partner at Mayer Brown in Chicago. Earlier in her career, she served as a Special Intern with the Foreign Affairs Department of the Kanagawa Prefectural Government in Yokohama, Japan (1989–1990).
Ms. Rexford serves on the outside advisory board of Argosy University’s Clinical Psychology Program and is a member of the Chicago Finance Exchange, an invitation-only organization comprised of women in Chicago finance. To view Ms. Rexford’s full biography, please visit: http://www.bakermckenzie.com/PatriciaRexford/
About Baker & McKenzie’s Tax Practice
Baker & McKenzie's global tax group is one of the most highly rated and recommended amongst law firms worldwide. With a worldwide team of more than 700 tax practitioners, economists and financial analysts in 39 countries, Baker & McKenzie’s Global Tax Practice provides a strong network of tax professionals offering innovative tax planning advice to multinational corporations, helping businesses design, implement and defend tax strategies for international operations and transactions. International Tax Review’s (ITR) World Tax 2011 directory ranked the Firm’s tax practice in 30 countries and Chambers Global 2011 ranked our tax practice in 17 jurisdictions and recognized 39 individual lawyers. In 2011, ITR’s Leading Tax Planning Practice survey ranked the Firm as “Top Tier” in 13 countries, including the US. ITR's Leading Tax Transactional Practice Survey ranked the Firm's tax practice as “Top Tier” in 11 countries, including the US.
About Baker & McKenzie
Founded in 1949, Baker & McKenzie advises many of the world’s most dynamic and successful business organizations through more than 3,800 locally qualified lawyers and over 5,800 professional staff in 69 offices in 42 countries. Baker & McKenzie is known for having a deep understanding of the language and culture of business, an uncompromising commitment to excellence, and world-class fluency in its client service.
Baker & McKenzie’s global revenues for the fiscal year ended June 30, 2011, were US$2.27 billion. Eduardo Leite is Chairman of the Firm’s Executive Committee. (
www.bakermckenzie.com)