Marc Levey

Marc M. Levey

Senior Counsel
Baker & McKenzie LLP

Biography

Marc Levey is a Senior Counsel in the New York office of Baker McKenzie. He has over 46 years of experience in international taxation and is a nationally recognized expert in his field, particularly in structuring and defending transfer pricing strategies. He has frequently been acknowledged by Euromoney as one of the "World's Leading Tax Advisors," included in its "Best of the Best" global tax experts. He also received a 2017 Albert Nelson Marquis Lifetime Achievement Award from Marquis Who's Who.

Practice Focus

Mr. Levey's practice focuses on transfer pricing and cross-border transactions; tax controversies and litigation; general corporate, international and partnership taxation, and restructuring multinational company's global operations. He has worked in various industries such as pharma/life sciences, financial institutions, energy, automotive, chemicals, electronics, consumer goods, gaming, fashion and luxury products. Mr. Levey serves as the Chair of the Firm's Fashion and Luxury Industry Practice Group and was the past Chair of the firm's Global Transfer Pricing Steering Committee.

Mr. Levey previously served as Tax Attorney with the International Tax Ruling Group of the National Office of the IRS from 1975 to 1977. He acted as Senior Trial Attorney with the Tax Division of the U.S. Department of Justice from 1977 to 1981. He was the Special Attorney to the Attorney General of the U.S. Department of Justice in 1982. Mr. Levey was formerly a partner in a Big Five firm, where he headed the transfer pricing practice for the greater metropolitan New York area and was a member of the firm's international task force. Mr. Levey also was a tax partner at a prominent New York-based law firm.

Representative Legal Matters

  • Serves as tax counsel on Club Med Sales, Inc. v. Commissioner.
  • Serves as tax counsel on Astra USA Inc. v. Commissioner.
  • Serves as tax counsel on Saint Gobain Corporation et al. v. Commissioner.
  • Serves as tax counsel on Frette SA v. Commissioner.
  • Serves as tax counsel on Andres Courage Inc. v. Commissioner.
  • Serves as tax counsel on Framatome Connectors USA v. Commissioner.
  • Serves as tax counsel on Brillembourg v. Commissioner.
  • Serves as tax counsel on the acquisition of PPC Broadband LLC and SKT International, B.V. by Belden, Inc.
  • Successfully negotiated conclusions to numerous IRS tax audits, appeals controversies, fast track appeals, competent authority matters and advance pricing agreements.

Professional Honors

  • Albert Nelson Marquis Lifetime Achievement Award, Marquis Who's Who 2017 
  • "Best of the Best" among international tax lawyers, Euromoney Legal Media Group
  • "Best of the Best among International Tax Lawyers" and “Leading World Transfer Pricing Expert”, International Tax Review
  • Listed lawyer, Madison’s Who’s Who
  • Listed lawyer, Best Lawyers in America
  • Listed lawyer, New York Area’s Best Lawyers

Professional Associations and Memberships

  • India's Taxmann - Advisory Board Member
  • BNA Foreign Tax Portfolio - Advisory Board Member
  • International Tax Journal - Advisory Board Member
  • New York University LL.M. Taxation Program - Adjunct Professor of Law
  • University of Cincinnati College of Law's Corporate Law Center - Advisory Board Member; Adjunct Professor of Law
  • American Bar Association - prior vice chairman, Affiliated and Related Tax Party Committee
  • American Bar Association - founding chairman, Transfer Pricing Committee
  • Journal of International Taxation - Advisory Board Member

Admissions

  • New York~United States (1988)
  • California~United States (1983)
  • Illinois~United States (1982)
  • District of Columbia~United States (1974)
  • Pennsylvania~United States (1973)

Education

  • University of Miami School of Law (LL.M., Honors) (1983)
  • University of Cincinnati (J.D.) (1972)
  • Wilkes University (B.S. Economics) (1969)

Languages

  • English
  • French
  • Editor, "US Taxation of Foreign Controlled Businesses," Warren, Gorham and Lamont, 2019

  • Co-author, "Transfer Pricing: Rules, Compliance and Controversy," CCH Incorporated, 5th Edition, December 2019

  • Co-editor, "Transfer Pricing and Intra Group Financing," IBFD Books, September 2012

  • Co-editor, "Transfer Pricing and Dispute Resolution," IBFD Books, July 2011

  • Co-editor, "Transfer Pricing and Customs Valuation", IBFD Books, August 2009