Mark A. Oates

Baker & McKenzie LLP


Mark A. Oates is listed in Euromoney’s Guide to the World’s Leading Transfer Pricing Advisers. He has litigated many high profile cases won by taxpayers in the last decade, and has actively consulted on other prominent cases. He has also handled various international tax litigation cases involving issues in tax treaty interpretation, Subpart F and foreign tax credit — and a host of domestic issues in mergers and acquisitions, leveraged buy-out, valuations, research credit, inventory and civil fraud. Mr. Oates is the immediate past chair of the Firm’s North America Tax Litigation Practice, and has an active pro bono criminal practice.

Practice Focus

Since 1985, Mr. Oates has concentrated on large case tax litigation. He also devotes a significant portion of his career to criminal defense, including defending corporations and individuals in tax fraud, money laundering, State and Commerce Department export issues and Classified Information Procedures Act cases. Mr. Oates has written numerous articles, and has served as a regular columnist and on the Advisory Boards of the Journal of Global Transactions and the Journal of Global Transfer Pricing.

Representative Legal Matters

  • Acted as lead counsel in Compaq transfer pricing case, in which the Tax Court rejected $232 million in IRS transfer pricing adjustments and awarded Compaq a $21.3 million income allocation based on issues conceded by the IRS.
  • Served as lead counsel in Compaq ADR case, which the Fifth Circuit reversed in favor of Compaq.

Professional Associations and Memberships

  • Illinois State Bar Association
  • Federal Bar Association
  • National Association of Criminal Defense Lawyers
  • Denver Bar Association
  • American Bar Association
  • American College of Tax Counsel
  • Colorado Bar Association
  • Chicago Bar Association


  • U.S. District Court, Colorado~United States (1987)
  • U.S. District Court, Northern District of Illinois~United States (1985)
  • U.S. Tax Court~United States (1985)
  • U.S. Court of Appeals, Fifth Circuit~United States (1985)
  • Illinois Supreme Court~United States (1985)
  • U.S. Supreme Court~United States
  • Colorado Supreme Court~United States
  • U.S. Court of Appeals, Second Circuit~United States


  • University of Michigan Law School (J.D., cum laude) (1985)
  • Indiana University (M.B.A.) (1982)
  • Indiana University (B.S., magna cum laude) (1981)


  • English