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Summer Austin

Partner
Baker & McKenzie LLP

Biography

Summer Austin joined Baker McKenzie’s Tax Practice Group in 2006. She has spent most of her time based in the Washington, DC office and was seconded to the Dusseldorf office during 2011 and 2012, where she worked with colleagues in Germany and throughout Europe.

Summer’s practice focuses on tax dispute resolution, transfer pricing, and international tax planning. Specific to the field of tax dispute resolution, Summer has significant experience in audit defense and tax litigation as well as Competent Authority matters and Advance Pricing Agreements. She has extensive experience in addressing transfer pricing issues, both within the planning and dispute resolution contexts. This includes analysis of intercompany services, IP transactions, value chain transformations, and evaluation of substance requirements in light of BEPS. Summer has also advised clients on a variety of international tax matters, including permanent establishment and other treaty matters, as well as impacts of US tax reform.

Prior to joining the Firm, Summer completed a judicial clerkship for Justice R. Malcolm Graham at the Massachusetts Appeals Court (2005-2006). She also taught as an Adjunct Professor at Georgetown University Law Center during the spring of 2010 and the spring of 2011.

Practice Focus

Summer has extensive experience advising clients on audit defense and tax litigation, as well as competent authority matters and advanced pricing agreements. She has also advised clients on various transfer pricing, permanent establishment and other treaty matters, as well as on a variety of tax planning issues.

Representative Legal Matters

  • Dorothy R. Diebold v. Commissioner, T.C. Memo 2010-238.
  • Salus Mundi Foundation, et al, v. Commissioner, T.C. Memo 2012-6.
  • CGG Americas, Inc. v. Commissioner, 147 TC 78 (2016)
  • Guardian Industries Corp. v. Commissioner, 143 TC 1 (2014)
  • Thomson Reuters America Corporation v. Commissioner, Docket No. 20288-16.
  • Trilogy, Inc. v. Commissioner, Docket. No. 12097-16.
  • Whirlpool Financial Corporation, et al, v Commissioner, Docket No. 13986-17.
  • Represented clients in the negotiation of Bilateral Advance Pricing Agreements and Competent Authority matters between the United States and various foreign jurisdictions, including Canada, Denmark, Germany, UK, India, China, Japan and Korea.

Professional Honors

  • Leading Lawyer ,International Tax Review – Tax Controversy Leaders Guide, 2017-2018
  • Leading Lawyer, International Tax Review – Women in Tax Leaders Guide, 2017-2018

Admissions

  • District of Columbia~United States (2006)
  • Texas~United States (2005)

Education

  • Harvard Law School (J.D.) (2005)
  • University of Texas at Austin (B.A. High Honors) (2002)
  • Technische Universität Dresden (2001)
  • San Martín De Tours (1998)

Languages

  • English
  • German
  • Spanish

Previous Offices

  • Dusseldorf