Michelle Phillips is an associate in Baker McKenzie’s Tax Practice Group in Washington, DC, where she handles domestic and international tax law controversies, investigations and dispute resolution. She is also an active participant in the Firm’s pro bono activities.
Ms. Phillips focuses her practice on corporate taxation, including cross-border taxation matters involving transfer pricing and regulatory matters. She has experience advising clients regarding banking secrecy investigations, the Foreign Account Tax Compliance Act, advance pricing agreements and transfer pricing disputes.
Representative Legal Matters
- Represented several Category 2, Category 3, and non-participating banks with respect to the US Department of Justice’s Swiss Bank Program, for which the Firm won the International Tax Review’s 2015 Americas Tax Award for Americas Tax Disputes Firm of the Year.
- Represented an automaker in bilateral advance pricing agreements involving the Internal Revenue Service and Japan tax authorities.
- Represented high-net-worth individuals involved in tax evasion investigations by DOJ.
- Advised a multinational industrial company on transfer pricing alignment (involving over 40 jurisdictions).
Professional Associations and Memberships
- State Bar of Wisconsin - Nonresident Lawyers Division
- Washington, D.C. State Bar - Tax Section
- American Bar Association - Tax Section
- District of Columbia~United States (2013)
- Wisconsin~United States (2012)
- Boston University School of Law (LL.M.) (2012)
- University of Melbourne (J.D.) (2011)
- Carleton College (B.A. Computer Science cum laude) (2004)
- Author, "Starving the Innovators: The IRS's Obtuse Meals Positions Ignore Congressional Silence and Modern Business Reality," Journal of Corporate Taxation (WG&L), Sept / Oct 2019