Bennett, Mary C. 06247

Mary C. Bennett

Senior Counsel
Baker & McKenzie LLP


Mary Bennett is a Senior Counsel in Baker McKenzie's Tax Practice Group. She has more than 40 years of international tax experience, including 30 years of private practice as well as senior positions with the US Treasury and the Organization for Economic Cooperation and Development (OECD). Ms. Bennett advises companies on international tax planning, controversy, and policy matters. She has particularly deep experience in tax treaty, transfer pricing, and international dispute resolution issues. Ms. Bennett regularly assists clients on tax policy issues before the Treasury Department, Congress, the OECD, the EC, and the UN.

From 2005-2011, Ms. Bennett served as Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division of the OECD's Centre for Tax Policy & Administration in Paris. While there, she oversaw updates to the OECD Model Tax Convention on mandatory arbitration, nondiscrimination, collective investment vehicles, and the attribution of profits to permanent establishments, and updates to the OECD Transfer Pricing Guidelines on comparability and profits methods, business restructuring, and intangibles.

Earlier in her career, Ms. Bennett served as Deputy International Tax Counsel at the US Treasury Department, where she led the US treaty negotiations with India, the Netherlands, and other countries, participated in developing international provisions of the 1986 through 1989 Tax Acts, worked on related IRS guidance, and represented the United States in multilateral fora. Prior to her service at Treasury, Ms. Bennett practiced international tax law with private firms in London (1979-81) and Boston (1981-85).

Representative Legal Matters

  • Represents groups of major companies from the high tech industry providing business input into the OECD Inclusive Framework/G20 project on Tax Challenges from the Digitalization of the Economy

  • Represents trade association of global custodian banks on issues relating to treaty-based withholding tax relief procedures around the world

  • Assisted companies affected by European Commission fiscal State aid investigations, including serving as an expert witness in a major case

  • Represented broad-based international coalition of large multinationals providing business input into the OECD/G20 project on Base Erosion and Profit Shifting (BEPS)

  • Obtained numerous discretionary IRS competent authority rulings granting relief from the anti-treaty shopping provisions of US. tax treaties for holding, financing, and licensing subsidiaries of European multinationals in various industries

  • Represented airline industry in achieving significant changes to proposed IRS regulations and OECD Commentary on reciprocal exemption for income from international operation of aircraft

  • Has advised multinational corporations in consumer products, publishing, financial services, information technology, pharmaceutical and other industries on planning and exposure with respect to the availability of treaty benefits

Professional Honors

She has been recognized as one of America's leading tax lawyers by Chambers USA, The International Who's Who of Corporate Tax Lawyers, and Euromoney's Guide to Women in Business Law, Women in Tax Leaders, and Guide to the World's Leading Tax Advisers.

Professional Associations and Memberships

  • IFA - Council for the USA Branch
  • ABA - Tax Section's Committee on US Activities of Foreigners and Tax Treaties
  • American Bar Foundation Fellow
  • American College of Tax Counsel Fellow
  • Business and Industry Advisory Committee (BIAC) Tax Committee and FATCA Business Advisory Group/TRACE Expert Group
  • United States Council for International Business Tax Committee
  • National Foreign Trade Council Tax Committee
  • Tax Coalition
  • Washington International Tax Study Group
  • Georgetown University Law Center - Adjunct Professor of Advanced International Tax (2001-2004)
  • Intertax Advisory Board


  • Massachusetts~United States
  • New York~United States
  • District of Columbia~United States
  • U.S. Tax Court~United States
  • U.S. Claims Court~United States
  • U.S. Supreme Court~United States


  • Boston University (LL.M. in Tax) (1985)
  • Columbia University (J.D.) (1979)
  • Harvard University (A.B., cum laude) (1976)


  • English
  • French
Ms. Bennett is a frequent speaker and writer on international tax issues and an active member of several tax professional organizations, including the International Fiscal Association (IFA) and the American Bar Association's (ABA's) Tax Section. She has published over 70 articles on international tax topics and has spoken at conferences in more than 20 countries, including events sponsored by the Tax Executives Institute (TEI), the United States Council for International Business (USCIB), the National Foreign Trade Council (NFTC), IFA, the ABA, the Federal Bar Association, the George Washington University/IRS International Tax Institute, the World Trade Institute, the Financial Executives Institute (FEI), the American Petroleum Institute (API), the Amsterdam Centre for Tax Law, the Max Planck Institute, and the University of Chicago Law School, among others. She delivered the 2005 David Tillinghast Lecture at New York University, the 2010 Frans Vanistendael Lecture at the University of Leuven in Belgium and the 2010 Maarten Ellis Lecture at the University of Leiden in the Netherlands.