Photo, Rafic H. Barrage

Rafic H. Barrage

Baker & McKenzie LLP


Rafic H. Barrage is a partner in Baker McKenzie’s Tax Practice Group. He has over 14 years of broad international tax planning and controversy experience. Mr. Barrage advises clients on a variety of issues, including restructuring and entity rationalization, IP migration, supply chain planning and principal structures, e-commerce and cloud computing, deferral and repatriation planning, foreign tax credit planning, and pre- and post-acquisition planning. Mr. Barrage is a recognized leader in his field by The Legal 500 (2010 and 2011) (described as one of the “impressive younger partners” and “technically very strong”) and as one of the Tax Controversy Leaders by the International Tax Review (2011 and 2012). Mr Barrage is an Adjunct Professor of Law at Georgetown University Law Center, where he teaches the international tax course, International Business Planning Workshop.

Practice Focus

Mr. Barrage regularly advises US corporations operating overseas and foreign corporations and individuals operating and investing in the United States on a broad range of international tax issues. Among other industries, Mr. Barrage’s practice focuses on the software and high-technology, pharmaceutical and life sciences, and the shipping (container and cruise line) industries.

Professional Associations and Memberships

  • New York State Bar Association - Tax Section
  • American Bar Association - Section on Taxation
  • District of Columbia Bar - Taxation Section, International Tax Committee
  • International Fiscal Association - USA Branch


  • District of Columbia~United States (2002)
  • New York~United States (2002)
  • U.S. Tax Court~United States (2002)
  • Georgia~United States (1999)


  • Georgetown University Law Center (LL.M. Taxation Distinction) (2000)
  • Georgetown University Law Center (LL.M. International & Comparative Law with Distinction) (1999)
  • Mercer University, Walter F. George School of Law (J.D.) (1998)
  • London Guildhall University (LL.B. Honours) (1995)


  • English


Co-author, “U.S.-to-Foreign Transfers Under Section 367(a),” BNA Tax Management Portfolio, 919-3rd T.M. (forthcoming)

Co-author, “US Supreme Court to Address Creditability of UK Windfall Tax,” International Tax Review, December-January, 2013


Presenter, “Taxation of Electronic Commerce: Issues in Cloud Computing” and panelist, “International Tax Conflicts in Electronic Commerce,” Foundation for International Tax, International Taxation Conference, Mumbai, India, December 2013

Speaker, “Cloud Computing Tax Issues,” Tax Executives Institute, Austin Chapter, Austin, TX, November 2013

Speaker, “OECD’s Work on Permanent Establishments,” The 2013 OECD International Tax Conference, Washington, DC, June 2013

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