FacultyFaculty/Author Profile
Mark J. Silverman

Mark J. Silverman

Steptoe & Johnson LLP

Washington, DC, USA


Mark J. Silverman is a partner in Steptoe's Washington office and former chair of the firm's Tax Group.  In 2005, Mr. Silverman was named one of the top ten tax lawyers in Washington by Legal Times.  He is a member of The American Law Institute, Tax Advisory Group for the Study of Subchapter C of the Internal Revenue Code.  He was formerly an advisor to the Committee on Ways and Means during their consideration of revisions to the corporate tax provisions of the Internal Revenue Code.  He also served as a Council member of the American Bar Association, Section of Taxation and was formerly chair of the Corporate Tax Committee. He chaired the Tax Section Task Force on Leveraged Buyouts and co-authored the Tax Advisors Planning Series on Financially Troubled Businesses. 

Mr. Silverman is a Fellow of the American College of Tax Counsel and is a member of the advisory boards of BNA Tax Management, Consolidated Returns Tax Report, M&A Tax Report, and Corporate Taxation magazines.  Mr. Silverman is on the Editorial Board of The American Journal of Tax Policy, and is on the Board of Trustees of the Southern Federal Tax Institute.  He also chairs the PLI annual consolidated returns program.

Mr. Silverman was formerly Corporate Tax Editor of The Journal of Taxation, and a member of the advisory boards of NYU Institute on Federal Taxation.  He was formerly a member of the Executive Committee of the New York State Bar Association and an attorney-advisor to Judge Samuel B. Sterrett of the United States Tax Court.

Mr. Silverman is a frequent speaker on tax matters and has published numerous articles on the subject.  In addition, he is an Adjunct Professor of Law at Georgetown University Law Center.

Mark J. Silverman is associated with the following items:
Treatise Chapters  Treatise Chapters Partnership Disguised Sale Rules - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Partnership Mixing-Bowl Issues (PowerPoint slides) - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Purchase Price Allocation Rules: Sections 1060, 338 and 197 - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Current Developments in Tax-Free and Taxable Acquisitions and Separations - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Comparison of the Intercompany Obligation Rules Under Former Treas. Reg. §1.1502-13(g) (1995), Former Prop. Treas. Reg. §1.1502-13(g) (1998), and Treas. Reg. §1.1502-13(g) (2008) - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The Consolidated Return Investment Basis Adjustment Rules - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Section 382: Fluctuation in Value - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The Consolidated Return Investment Basis Adjustment Rules—Study Problems - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Recent Developments in the Step Transaction Doctrine - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Section 338 - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Tax Treatment of Reorganization Costs - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Section 384 of the Internal Revenue Code of 1986 - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Corporate Divisions Under Section 355 - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The Consolidated Unified Loss Rules - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The Fourth Time’s a Charm—Temporary Section 355(e) Regulations Provide Helpful Guidance to Taxpayers - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The Section 355(d) Regulations: Narrowing the Scope of an Overly Broad Statute - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Spin-Offs: Continuing Relationships Between Distributing & Controlled - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Section 382 - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Current Developments in Tax-Free Corporate Reorganizations - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Intercompany Transaction Problems - The Corporate Tax Practice Series, Wednesday, February 08, 2017
A New Form of Obscenity? Sorting Through the Federal Circuit’s “We Know It When We See It” Ruling in Coltec - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The Section 382 Consolidated Return Regulations - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Assessing the Value of the Proposed “No Net Value” Regulations - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Section 338(h)(10) - The Corporate Tax Practice Series, Wednesday, February 08, 2017
“Spin-Offs”: The Anti-Morris Trust and Intragroup Spin Provisions - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Use of Limited Liability Companies in Corporate Transactions - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The Pre-Reorganization Continuity of Interest Regulations - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The S Corporation Rules and the Use of S Corporations as Acquisition Vehicles - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The Regulations Governing Intercompany Transactions Within Consolidated Groups - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Final Section 355(e) Plan Regulations—The Final Chapter in the Saga - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The Future of Tax Planning? From Coltec and “You Know It When You See It” to Schering-Plough and “Assimilation with Applicable Tax Laws” - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Section 197 and Partnership Transactions - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Continuity of Interest and Continuity of Business Enterprise Regulations - The Corporate Tax Practice Series, Wednesday, February 08, 2017
The S Corporation Rules and the Use of S Corporations as Acquisition Vehicles - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Partnership Mixing-Bowl Issues (PowerPoint slides) - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Partnership Disguised Sale Rules - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Section 197 and Partnership Transactions - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Use of Limited Liability Companies in Corporate Transactions - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Web Segment  Web Segment Investment Adjustments and Related Issues - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Acquisition and Separation Issues in Consolidation - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Corporate Transactions Open Discussion - Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017, Friday, October 27, 2017
Taxable Transaction Alternatives - Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017, Friday, October 27, 2017
Course Handbooks  Course Handbooks Consolidated Tax Return Regulations 2017
CHB Chapters  CHB Chapters The Pre-Reorganization Continuity of Interest Regulations - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Continuity of Interest and Continuity of Business Enterprise Regulations - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Current Developments in Tax-Free and Taxable Acquisitions and Separations - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Section 384 of the Internal Revenue Code of 1986 - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Intercompany Transaction Problems - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
The Section 382 Consolidated Return Regulations - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Assessing the Value of the Proposed “No Net Value” Regulations - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Current Developments in Tax-Free Corporate Reorganizations - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
A New Form of Obscenity? Sorting through the Federal Circuit’s “We Know It When We See It” Ruling in Coltec - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Investment Adjustments & Related Issues (PowerPoint slides) - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Recent Developments in the Step Transaction Doctrine: Issues and Examples - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
The Consolidated Unified Loss Rules - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Comparison of the Intercompany Obligation Rules Under Former Treas. Reg. § 1.1502-13(g) (1995), Former Prop. Treas. Reg. §1.1502-13(g) (1998), and Treas. Reg. §1.1502-13(g) (2008) - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
The Regulations Governing Intercompany Transactions Within Consolidated Groups - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Section 382 - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
The Consolidated Return Investment Basis Adjustment Rules—Study Problems - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
“Spin-Offs”: The Anti-Morris Trust and Intragroup Spin Provisions - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Section 382: Fluctuation in Value - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Acquisition and Separation Issues in Consolidation (PowerPoint slides) - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
The Consolidated Return Investment Basis Adjustment Rules - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Final Section 355(e) Plan Regulations—The Final Chapter in the Saga - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Section 338(h)(10) - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
The Fourth Time’s a Charm—Temporary Section 355(e) Regulations Provide Helpful Guidance to Taxpayers - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Section 338 - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
The Section 355(d) Regulations: Narrowing the Scope of an Overly Broad Statute - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Use of Limited Liability Companies in Corporate Transactions - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Corporate Divisions Under Section 355 - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
The Future of Tax Planning? From Coltec and “You Know It When You See It” to Schering-Plough and “Assimilation with Applicable Tax Laws” - Consolidated Tax Return Regulations 2017, Wednesday, February 15, 2017
Partnership Disguised Sale Rules - Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2017, Friday, June 09, 2017
Section 338 - Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017, Wednesday, October 18, 2017
Taxable Transaction Alternatives (PowerPoint slides) - Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017, Wednesday, October 18, 2017
Section 338(h)(10) - Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017, Wednesday, October 18, 2017
Use of Limited Liability Companies in Corporate Transactions - Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017, Wednesday, October 18, 2017
MP3 Audio  MP3 Audio Investment Adjustments and Related Issues - Investment Adjustments and Related Issues , Wednesday, February 15, 2017
Acquisition and Separation Issues in Consolidation - Acquisition and Separation Issues in Consolidation, Wednesday, February 15, 2017
Corporate Transactions Open Discussion - Corporate Transactions Open Discussion, Friday, October 27, 2017
Taxable Transaction Alternatives - Taxable Transaction Alternatives, Friday, October 27, 2017
MP4 - Mobile Video Seg  MP4 - Mobile Video Seg Acquisition and Separation Issues in Consolidation - Acquisition and Separation Issues in Consolidation, Wednesday, February 15, 2017
Investment Adjustments and Related Issues - Investment Adjustments and Related Issues , Wednesday, February 15, 2017
Corporate Transactions Open Discussion - Corporate Transactions Open Discussion, Friday, October 27, 2017
Taxable Transaction Alternatives - Taxable Transaction Alternatives, Friday, October 27, 2017
On-Demand Web Programs  On-Demand Web Programs Consolidated Tax Return Regulations 2017, Tuesday, February 21, 2017, New York, NY
Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017, Wednesday, November 01, 2017, New York, NY
Transcripts  Transcripts Corporate Transactions Open Discussion - Corporate Transactions Open Discussion, Friday, October 27, 2017
Live Seminar  Live Seminar Consolidated Tax Return Regulations 2018, Tuesday, February 20, 2018, New York, NY
Live Webcast  Live Webcast Consolidated Tax Return Regulations 2018, Tuesday, February 20, 2018, New York, NY
PLI Grpcast-Live Web  PLI Grpcast-Live Web Consolidated Tax Return Regulations 2018, Tuesday, February 20, 2018, Atlanta, GA
Consolidated Tax Return Regulations 2018, Tuesday, February 20, 2018, Cleveland, OH
Consolidated Tax Return Regulations 2018, Tuesday, February 20, 2018, Philadelphia, PA
Consolidated Tax Return Regulations 2018, Tuesday, February 20, 2018, Pittsburgh, PA
Consolidated Tax Return Regulations 2018, Tuesday, February 20, 2018, Mechanicsburg, PA
Consolidated Tax Return Regulations 2018, Tuesday, February 20, 2018, New Brunswick , NJ
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