J. David Varley is Senior Manager of the new Treaty Assistance and Interpretation Team in the IRS Large Business and International Division. The Treaty Assistance and Interpretation Team functions as an operation within the Office of the Deputy Commissioner (International) and the Office of the U.S. Competent Authority, and under the direction of the Assistant Deputy Commissioner (International). The Team is responsible for addressing all tax treaty and tax information exchange agreement issues and cases arising within the U.S. Competent Authority program, other than those pertaining to transfer pricing and allocation. Mr. Varley specializes in treaty interpretation, enforcement and administration, including exchange of information matters, and the income taxation of persons and activities in the U.S. territories.
Mr. Varley has extensive and broad experience within the IRS and its Office of Chief Counsel. Prior to his current position, he was a staff attorney to the Deputy Commissioner for Services and Enforcement, Senior Counsel in Branch 7 of the Office of Associate Chief Counsel (International), and senior team leader in the IRS Advance Pricing Agreement Program.
Before joining the Service, Mr. Varley practiced tax law for several years in the private sector. Mr. Varley has his B.A. cum laude from West Virginia University, his J.D. summa cum laude from the University of Arizona College of Law, and his LL.M. in Taxation from the University of Florida Levin College of Law. Mr. Varley is a member of the Pennsylvania and Arizona Bars.