FacultyFaculty/Author Profile

Philip R. West

Steptoe & Johnson LLP

Washington, DC, USA


Philip R. West is a partner and co-chair of the tax practice in the Washington office of Steptoe & Johnson LLP, where he focuses mainly on international tax issues for both domestic and foreign clients. Mr. West also serves on Steptoe's Strategic Planning and Diversity Committees, and is a past member of the firm's Executive Committee.

With 25 years in practice, Mr. West has extensive practical experience minimizing the tax cost of international business operations and transactions. He has deep substantive knowledge of income deferral, foreign tax credit, transfer pricing, and tax treaty matters, as well as the tax aspects of mergers, acquisitions, joint ventures, and financings, investment funds, and tax minimization structures and transactions. He also devotes significant attention to helping clients favorably resolve controversies with, and obtain rulings from, the IRS, and he has been particularly active with competent authority matters and with attest auditors on FIN 48 and other financial statement issues. Mr. West also has extensive practical experience dealing with the Treasury Department and Congress on both technical matters and on issues of broad policy significance.

Mr. West served for nearly four years as the Treasury Department's International Tax Counsel, the senior international tax lawyer in the US government. In that position, he played a central role in virtually every policy, legislative, and regulatory development in the international tax area and led tax treaty negotiations, discussions, and ratification efforts involving countries throughout the world. Mr. West also played a major role in the US work at the Organization for Economic Cooperation and Development (OECD) and led official delegations there and on other missions. He has practical experience with many foreign tax systems and good relationships with foreign tax officials and private practitioners around the world. He is regularly called on to advise government officials with respect to sensitive and complex tax matters.

Earlier in his career, Mr. West litigated tax cases with the Justice Department, advised Judge Carolyn Miller Parr as a Tax Court clerk, counseled financial institutions and other clients with a Wall Street law firm, and practiced in the national office of an international accounting firm.

Mr. West is a frequent speaker and author on international and domestic tax subjects, addressing both professional and academic audiences.

Philip R. West is associated with the following items:
Treatise Chapters  Treatise Chapters Antiabuse Rules and Policy: Coherence or Tower of Babel? - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Table of Contents - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Special Document Issues in International Examinations - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Early Preparation and Documentation for Audit and Controversy - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Discovery in International Tax Cases - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
IRS Appeals and Special Appeals Procedures - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Handling the International Examination - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Post-Appeals Litigation Options and Choice of Forum - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Pre-Audit Planning, Including Document Retention and Spoliation - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Exchange of Information - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Index - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Advance Pricing Agreements - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Trial and Appellate Practice - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
The Role of the Competent Authority: Mutual Agreement Procedures - International Tax Controversies: A Practical Guide (2018 Edition), Monday, August 21, 2017
Treatise  Treatise International Tax Controversies: A Practical Guide (2018 Edition) - International Tax Controversies: A Practical Guide (2017 Edition)
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