FacultyFaculty/Author Profile

Mary C. Bennett

Baker & McKenzie LLP

Washington, DC, USA


Mary C. Bennett recently completed a 6-year tenure as Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division in the OECD's Centre for Tax Policy & Administration in Paris and rejoined Baker & McKenzie LLP as a partner in the Firm's Washington, DC office, where she previously practiced as a partner from 1990 to 2005. Her practice focuses on tax planning for multinational corporations.  She also represents clients in private letter ruling, competent authority, and tax controversy matters before the IRS and in tax policy matters before various governmental agencies and international organizations.

At the OECD, she oversaw the organization's work on its Model Tax Convention and its Transfer Pricing Guidelines and was active in deepening the OECD's dialogue on tax treaty and transfer pricing matters with non-OECD countries. Her work included the introduction of arbitration and a new Article 7 (Business Profits) into the Model Tax Convention, revision of the guidance on comparability and profits methods and introduction of new guidance on business restructurings in the Transfer Pricing Guidelines, completion of the Report on the Attribution of Profits to Permanent Establishments, and supervision of the work on the Treaty Relief and Compliance Enhancement (TRACE) project.

Between 1985 and 1990, she was the Deputy International Tax Counsel at the U.S. Treasury. Prior to her time at Treasury, she practiced international tax law with law firms in London and Boston.

Mary holds an A.B. from Harvard University (1976), a J.D. from Columbia Law School (1979), and an LL.M. in Taxation from Boston University (1985). She taught Advanced International Tax at Georgetown University (2001-2004) and is a regular speaker and author on international tax issues.

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