Sahar Zomorodi

Sahar Zomorodi

Associate
Baker & McKenzie LLP

Biography

Sahar Zomorodi is a member of the Firm’s North America Tax Practice Group in New York, where she focuses on a broad range of US and international taxation matters, including tax planning and transactions, transfer pricing, and audit defense and controversy for multinational corporations. Ms. Zomorodi has recently spent a year at the Firm's Amsterdam office, where she provided US tax advice to European based clients.

Ms. Zomorodi has over 14 years of experience in transfer pricing in the private sector and the Internal Revenue Service. Prior to joining the Firm, Sahar was an economist and team leader with the IRS's Advance Pricing and Mutual Agreement Program in Washington, DC, where she developed, negotiated, and defended the US position on international double tax disputes (under Competent Authority proceedings) and drafted advance pricing agreements.

Ms. Zomorodi is an active member of the Firm's Pro Bono and Diversity Committees.

Practice Focus

Ms. Zomorodi advises clients on US federal income taxation with a focus on international tax planning, transfer pricing, and tax controversy.

Representative Legal Matters

Ms. Zomorodi has extensive experience in providing clients with comprehensive business-focused solutions in structuring, managing, and implementing global projects - including mergers, acquisitions, IP planning, restructurings, and post-acquisition integration transactions. These projects often require coordinating cross-disciplinary advice relating to tax, corporate, employment, regulatory, and intellectual property matters across multiple jurisdictions. In this context, Ms. Zomorodi has:

  • Assisted in drafting and filing private letter ruling requests to the IRS relating to intercompany transfer of assets.

  • Advised on and prepared intercompany agreements, including IP licensing, platform contribution transactions, and cost sharing arrangements for multinational corporations in the pharmaceutical, medical devices, high technology, and retail industries.

  • Advised multinational corporations with respect to permanent establishment exposure and the availability of treaty benefits.

  • Represented US based retailers in transfer pricing controversy matters, with a focus on China Business Trust structures.

Professional Associations and Memberships

  • Iranian American Bar Association, New York Chapter

Admissions

  • New York~United States (2014)

Education

  • American University (J.D.) (2013)
  • George Washington University (B.S. Economics, magna cum laude) (2007)
  • George Washington University (B.A. International Affairs, magna cum laude) (2007)

Languages

  • English
  • Farsi

Author, “Updates on US's Competent Authority Arrangements,” Baker McKenzie Tax News and Developments Newsletter, October 2020

Author, “OECD Issues Unified Approach Proposal for Pillar I,” Baker McKenzie Tax News and Developments Newsletter, November 2019

Author, “Heightened Scrutiny In Future Ruling Requests,” Baker McKenzie Tax News and Developments Newsletter, December 2017

Author, "OECD Releases Discussion Drafts on BEPS Action Items 4 and 14," Baker McKenzie Tax News and Developments Newsletter, February 2015

Speaker, "Introduction to Transfer Pricing," Bloomberg BNA Principles of International Tax Seminar, NYC, November 2014

Speaker, "Computing Direct and Indirect Foreign Tax Credit Benefits," Bloomberg BNA U.S. International Tax Planning Seminar, July 2014