Tamara A. Levin

Tamara has extensive experience representing US and foreign multinational companies in a variety of technology-based industries, including software, semiconductor, communications, biotechnology, medical equipment, and online service businesses.

Tamara advises companies on tax aspects of intercompany transactions, including analyzing and documenting transactions and developing pricing policies. Tamara assists clients to comply with complex US and international transfer pricing rules and to anticipate and prepare for global controversies in this area. Tamara also provides tax planning advice for mergers, acquisitions and post-acquisition integrations.

• Acted as lead transfer pricing counsel in connection with the integration of intangible property assets, following multibillion dollar acquisitions by an online service business.
• Advised on strategic issues involving the merging of multiple cost sharing arrangements for a communications company.
• Oversaw the drafting of agreements and transfer pricing reports to document intercompany arrangements in connection with business restructurings, transfers of products, and sales of intangible property for a semiconductor company.
• Advised on alternatives for structuring intercompany transactions of a foreign multinational online service business.
• Advised medical technology company on tax matters in connection with cross-border asset divestiture.
• Participated in controversy defense of “buy-in” under a cost sharing arrangement for a semiconductor company.
• Analyzed revenue characterization of new product offering of a consumer electronic company.
• Advised on effectively connected income, subpart F and investment in US property issues, as well as issues under the Tax Cuts and Jobs Act such as application of BEAT to various intercompany arrangements.
• Advised on tax consequences of legal entity reorganizations of a medical equipment company.

• State Bar of California - Member

• Palo Alto