Elizabeth Stevens is a Member of the Firm and practices across the International Tax, Tax Controversies, and Business, Investment & Transactional Tax groups.  Her practice spans international tax planning and advocacy for multinational corporations, as well as advising clients on federal income tax structuring and transactional representation for partnerships, LLCs, and S-corporations.

Ms. Stevens’ experience in international tax matters primarily involves transfer pricing and U.S. outbound and inbound investment planning and structuring.  In the transfer pricing space, she advises corporate clients on planning, documentation, and compliance, with a particular focus on negotiating Advance Pricing Agreements (APAs).  Ms. Stevens regularly represents clients seeking Competent Authority assistance under bilateral income tax treaties and also advises on other treaty-related matters, such as the creation and taxation of permanent establishments and eligibility for treaty benefits.

For both cross-border and U.S.-based clients, Ms. Stevens provides representation in acquisitions and buy-out transactions, including the drafting and negotiation of partnership and LLC operating agreements.  She also advises partnerships and S-corporations on federal income tax planning, structuring, and compliance matters. 

In recent years, Ms. Stevens’ international tax practice has emphasized advice regarding the implications of recent and proposed U.S. and global tax reform initiatives for particular business lines and models and on alternatives for mitigating resulting risk and uncertainty.  She also counsels multinational enterprises on the federal income tax consequences of restructuring proposals and provides strategic guidance in transfer pricing and other federal income tax controversy matters. 


Before joining Caplin & Drysdale, Ms. Stevens practiced at a regional law firm in California, where she assisted corporate and individual clients with business transactions, estate planning, employment matters, and civil litigation. Ms. Stevens has also practiced as a litigation fellow at Americans United for Separation of Church and State in Washington, D.C., where she represented plaintiffs in federal court lawsuits involving free speech and religious discrimination claims. Ms. Stevens also served as a law clerk to then-Chief Judge Royce Lamberth of the U.S. District Court for the District of Columbia and Judge Robert A. Wherry, Jr. (Ret.) of the U.S. Tax Court.

Ms. Stevens earned an LL.M. in Taxation from New York University School of Law and graduated first in her class from California Western School of Law. Before earning her law degree, Ms. Stevens served as a U.S. naval officer. She received her commission through the Navy's ROTC program and holds a degree in international political economy from Georgetown University.

Admissions & Education

Bar & Court Admissions
  • California
  • District of Columbia
  • U.S. Supreme Court
  • U.S. Tax Court

LL.M. in Taxation, New York University School of Law, 2014, Harry J. Rudick Memorial Award

J.D., California Western School of Law, 2008, summa cum laude

B.S. in Foreign Service, Georgetown University, 2002, magna cum laude

Recognitions & Noteworthy

Honors & Recognitions
  • The Legal 500, Recommended 2020-Present

Professional Activities & Affiliations

Other Professional Affiliations

Council Director, American Bar Association, Section of Taxation

Member, U.S. Council for International Business

Member, Caplin & Drysdale’s Diversity, Equity & Inclusion Committee  

Former Chair, American Bar Association, Section of Taxation, Transfer Pricing Committee

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Speaking Engagements
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