Bennett, Mary C. 06247

Mary C. Bennett

Baker & McKenzie LLP


Mary Bennett is a partner in Baker & McKenzie's Tax Practice Group. She has more than 30 years of international tax experience, including senior positions with both the US Treasury and the Organization for Economic Cooperation and Development (OECD). Ms. Bennett has been recognized as one of America’s leading tax lawyers by Chambers USA.

Practice Focus

Ms. Bennett advises US and foreign based multinational clients on international tax planning, controversy, and policy matters. She has particularly deep experience in tax treaty, transfer pricing, and international dispute resolution issues. She previously served as the Head of the Tax Treaty & Transfer Pricing Division at the OECD, leading that organization’s work to achieve international consensus on policies to avoid double taxation and to apply the arm’s length principle. She also served as the US Treasury’s Deputy International Tax Counsel, with responsibility for heading tax treaty negotiations with numerous countries and developing US legislative and regulatory policy on international tax questions. In her more than 20 years of private practice, Ms. Bennett has advised companies on the structuring of international operations and represented clients in private letter ruling, competent authority, and tax controversy matters before the IRS and in tax policy matters before the Treasury Department, Congress, and the OECD. She has also participated in litigating foreign tax credit, captive insurance, and other issues in the courts.

Professional Associations and Memberships

  • Georgetown Univ. Law Center - Adjunct Professor of Advanced International Tax (2001-2004)
  • American Bar Association - Committee on U.S. Activities of Foreigners and Tax Treaties, Tax Section
  • United States Council for International Business - Tax Committee
  • The Tax Coalition - Member
  • International Fiscal Association - Council Member for the U.S.A. Branch
  • National Foreign Trade Council - Tax Committee
  • Senate Finance Committee's International Tax Working Group - Advisor (2002-2003)
  • BIAC - Tax Committee


  • U.S. Supreme Court~United States (1994)
  • U.S. Claims Court~United States (1991)
  • U.S. Court of Appeals, Eleventh Circuit~United States (1991)
  • District of Columbia~United States (1991)
  • U.S. Tax Court~United States (1990)
  • U.S. District Court, District of Massachusetts~United States (1983)
  • New York~United States (1980)
  • Massachusetts~United States (1979)


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


  • English
  • French

Co-author, “The Arm’s Length Principle and Developing Economies,” Tax Management Transfer Pricing Report, 20 October 2011

Author, “Article 7 – New OECD Rules for Attributing Profit to Permanent Establishments,” The 2010 OECD Updates: Model Tax Convention and Transfer Pricing Guidelines – A Critical Review, Kluwer, September 2011

Co-author, “Managing Cross-Border Tax Disputes,” Taxes, June 2011

Author, “La mise à jour 2010 du modèle de convention fiscale de l'OCDE,” Revue de Droit fiscal, 30 September 2010