Lawyer Bio : Zion Levi

Zion Levi

Washington, DC

Zion Levi's practice encompasses all facets of federal income tax law, with a particular focus on international tax issues including transfer pricing, international mergers and acquisitions, and inbound and outbound investments and transactions. Mr. Levi has extensive experience in planning optimal domestic and international tax strategies and structures, and in successfully representing taxpayers in controversies before the Internal Revenue Service (IRS), both at the audit stage and before IRS Appeals. Many of Mr. Levi’s clients are part of the Coordinated Industry Case (CIC) Program of the IRS's Large and Mid-Size Business (LMSB) division, while other clients include special purpose business entities and high net-worth individuals. Mr. Levi’s clients are both foreign and U.S.-based, and belong to a variety of industries, including banking and finance, computer software, electronic and furniture manufacturing and distribution, real estate (including REITs), automotive, export and import, advertising and marketing, and defense. In addition, Mr. Levi has substantial experience with the IRS’s various Voluntary Compliance Programs and, when appropriate, successfully represents clients before the IRS's Criminal Investigation Division (CID).

Mr. Levi's recent engagements include: 

  • Structuring and negotiating the acquisition of a multinational electronic manufacturing and distribution group of companies with operations in the Far East, the United States and Europe. 
  • Designing intercompany transfer pricing programs (including preparation of contemporaneous documentation). 
  • Structuring and negotiating the reorganization of a multinational advertising and marketing group of companies with operations in the United States, United Kingdom, China, Germany and Italy, among other jurisdictions. 
  • Securing Advance Pricing Agreements (APA). 
  • Structuring tax efficient cross-border transactions (both inbound and outbound), while taking advantage of various Tax Treaties.
  • Securing favorable settlements for taxpayers before the IRS's CID.

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Professional Activities

Bar Associations: American Bar Association (ABA), Section of Taxation

  • Committee on Transfer Pricing
  • Banking & Savings Institutions Committee
  • Committee on Foreign Activities of U.S. Taxpayers
  • Committee on US Activities of Foreigners & Tax Treaties

Admitted to the bar, 1996, New York; 1998, District of Columbia.

Education

B.A., magna cum laude, 1992, Fordham University; J.D., cum laude, 1995, Brooklyn Law School; Articles Editor, Brooklyn Journal of International Law; LL.M., 1996, New York University School of Law.

Prior Legal Experience

Of Counsel, Powell Goldstein LLP, 2003-2005, Washington, DC; Counsel, 2002-2003, Tax Associate, 1997-2001, Miller & Chevalier Chartered, Washington, DC; Tax Associate, Piper & Marbury LLP, 1996-1997, New York, NY.

Publications

"Transfer Pricing: Alternative Practical Strategies," 890 BNA Tax Management Portfolios, Chapter 9, Cost Sharing Arrangements, October 2007;

"Procedural Rules for Claiming Set-offs Continue to Emphasize the Importance of Maintaining Contemporaneous Documentation," Vol. 83, No. 10, Taxes-The Tax Magazine 53, October 2005; (Republished on the Social Science Research Network's eLibrary, December 2005)

"Exploring the Implications of State Formless Conversions After Rev. Rul. 2004-59," 82 Taxes-The Tax Magazine 51, September 2004;

"Are All Things Royal in Royalties? A Comparison Between Two Treaties," 32 Tax Notes Int'l 1015, December 15, 2003;

"Ninth Circuit Grapples With Marketing Intangibles, Overturns Tax Court in DHL Inc. v. Commissioner," 41 Tax Management 427, October 2002;

"The Financial Products Provisions of the Taxpayer Relief Act of 1997," Tax Management Memo 2-295, November 1997.

Additional Information

Languages
Fluent in Hebrew