Elizabeth Stevens is a Member of the Firm and practices across the International Tax, Tax Controversies, and Business, Investment & Transactional Tax groups. Her client representations span international tax and transfer pricing planning and advocacy for multinational corporations; U.S. investment and business structuring and transactional advice for foreign corporate groups; and domestic and cross-border tax structuring, transactional, and compliance advice to high net-worth individuals and their privately held businesses.
Services
In the transfer pricing space, Ms. Stevens advises corporate clients on planning, documentation, and compliance, with a particular focus on dispute resolution and prevention and tax certainty processes such as the Mutual Agreement Procedure (MAP) and Advance Pricing Agreements (APAs). Ms. Stevens also regularly advises on other treaty-related matters, such as the creation and taxation of permanent establishments, relief from double taxation for U.S. citizens resident outside the United States, corporate and individual tax residency determinations, and eligibility for treaty benefits.
Outside the treaty context, Ms. Stevens’ experience in international tax matters emphasizes comprehensive planning and advisory services for individuals who are or wish to become bona fide residents of Puerto Rico and the U.S. Virgin Islands. She also provides tax planning and structuring advice and transactional representation to individual and corporate clients, with a focus on foreign companies, individuals, and tax-exempt persons investing or conducting business in the United States. Her recent experience includes advice to employees and employers on the tax implications of remote and mobile work arrangements.
In the cross-border and purely domestic contexts, Ms. Stevens assists partnerships, LLCs, and S-corporations with M&A transactions, business restructurings, and drafting and negotiation of stock and asset purchase agreements, partnership and LLC operating agreements, employment agreements, and other key transaction documents. She also advises tax partnerships and S-corporations on federal income tax planning, structuring, and compliance matters.
Highlights
Ms. Stevens began her professional life as a U.S. naval officer. After earning her law degree, she practiced for several years in civil litigation, estate planning, employment matters, and general business advisory and transactions. Her roles before joining Caplin & Drysdale included positions at a private law firm and a nonprofit organization and clerkships with 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 discovered her calling as a tax lawyer at New York University School of Law, where she earned an LL.M. in Taxation, but continues to leverage her broader lawyering experience in serving as a trusted counselor for clients on their legal matters.
Admissions & Education
Bar & Court Admissions
- California
- District of Columbia
- U.S. Supreme Court
- U.S. Tax Court
Education
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 2020-2024
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 Talent Strategy Committee
Former Chair, American Bar Association, Section of Taxation, Transfer Pricing Committee
