Mark R. Martin
is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Houston office. He is the head of the Firm’s Transfer Pricing Practice.
Mark represents multinational enterprises and other clients in international transfer pricing and tax controversy matters relating to crossborder operations, investments and transactions. He regularly advises clients on competent authority cases, negotiates advance pricing agreements, and provides guidance on FIN 48 (FASB ASC 740-10) matters, with a particular focus on their effect on transfer pricing, permanent establishment and other international tax issues.
Mark also represents clients before the IRS and other tax authorities in a broad range of domestic and international tax controversies and in litigation. Earlier in his legal career he served as an attorney advisor to Judge Carolyn Miller Parr of the U.S. Tax Court.
Recognized for his client service and contributions to the practice of tax law, Mark has been listed among the top lawyers in the field by Chambers USA
and The Best Lawyers in America
, has been named a Texas Super Lawyer by Law & Politics Media Inc. and Texas Monthly, and has earned the AV Preeminent Rating (5.0 out of 5.0) by Martindale-Hubbell.
Mark is the author and co-author of numerous articles and other publications on tax issues, including several treatises published by Warren Gorham & Lamont: Transfer Pricing Strategies, U.S. International Transfer Pricing, U.S. International Taxation—Practice and Procedure and Corporate Income Tax Accounting
. Mark’s articles have also been seen in The National Law Journal, Texas Tax Law, the Journal of International Taxation
and Asia-Pacific Tax Bulletin,
among other publications.
Mark is a regularly featured speaker at conferences, seminars, meetings and other events, where he lectures on current developments in transfer pricing, tax controversies and other emerging international tax issues. He has appeared at gatherings of the American Bar Association, the State Bar of Texas, the International Fiscal Association, the Tax Executives Institute, the BNA Tax Management Advisory Board, the International Association of Drilling Contractors, the American Petroleum Institute, the Southwest CEO Council, the Council for International Tax Education, the Alliance for Tax, Legal & Accounting Seminars, and other groups. Mark is a former adjunct professor in the Graduate Tax Program at the University of Cincinnati, where he taught courses on Partnership Tax and Corporate Mergers, Acquisitions and Consolidated Returns.
Mark is a member of the American Bar Association, Tax Section, for which he is Chair of the Transfer Pricing Committee. He is also a member of the State Bar of Texas and formerly served on its Tax Section Council, and is the former Chairman of the International Tax
Committee (Tax Section).
Mark is admitted to practice in Texas and before the U.S. District Court for the Northern District of Texas, the U.S. Court of Appeals for the Fifth Circuit, U.S. Court of Federal Claims, and the U.S. Tax Court.
- Represented a multinational entertainment enterprise in a U.S. and Japan competent authority proceeding.
- Represented a multinational engineering and construction enterprise in a U.S. and United Kingdom bilateral advance pricing agreement.
- Represented a multinational manufacturing enterprise in a U.S. and Canada bilateral advance pricing agreement.
- Represented a multinational service company in a U.S. and New Zealand competent authority proceeding.
- Represented a multinational chemical company in a U.S. and Japan competent authority proceeding and a related bilateral advance pricing agreement.
- Represented a multinational oil field service company in obtaining an IRS pre-filing agreement on international tax issues.
- Represented a multinational engineering enterprise in a case before IRS Appeals.
- Represented a multinational oil field service company in a U.S. and Canada competent authority proceeding
- Represented a multinational oil field service company in an IRS fast track process.
- Represented an oil field service company in an IRS compliance assurance process (CAP).
- Washington University School of Law, LL.M., 1993
- University of Toledo College of Law, J.D., 1992
- University of Cincinnati, B.A., 1989