Steven P. Hannes is Senior Counsel to Caplin & Drysdale's International Tax and Tax Controversies practice groups.  Mr. Hannes joined the firm in March 2018.


Mr. Hannes advises U.S.- and foreign-based multinational corporations on developing their cross-border transactions, and counsels multinational companies in tax controversies. He represents clients on matters at the Audit, Appeals, Competent Authority and the Advance Pricing Agreement offices of the Internal Revenue Service (IRS). Mr. Hannes is recognized nationally for creating and defending structures and contractual arrangements that involve intra-group transactions and prices for intellectual property, goods and services. He has also presented expert testimony on tax treaties in court.

Mr. Hannes counsels clients in a range of industries, including automotive, heavy machinery, pharmaceuticals and chemicals, computers and electronics, and consumer goods such as beverages and photo equipment. He also advises clients involved in research, technical, and other services.


Mr. Hannes served as associate international tax counsel in the Office of the Assistant Secretary (Tax Policy) of the U.S. Treasury Department. He helped negotiate income tax treaties and protocols with, among others, the governments of Canada and the United Kingdom. Before joining Treasury, Mr. Hannes was chief of the international rulings group in what was then called the Office of the Assistant Commissioner (Technical) of the IRS.

Mr. Hannes speaks frequently at international and national conferences, and has authored many articles on international tax topics.

Admissions & Education

Bar & Court Admissions
  • District of Columbia

J.D., New York University School of Law, 1970

B.A., Amherst College, 1967

Recognitions & Noteworthy

Honors & Recognitions
  • Best Lawyers in America, 2007-Present
  • Expert Guides' The Best of the Best, Tax Advisors for Transfer Pricing
  • International Who's Who of Business Lawyers
  • International Who's Who of Corporate Tax Lawyers
  • The Legal 500

Government Service

Associate International Tax Counsel, Office of the Assistant Secretary (Tax Policy), U.S. Department of Treasury

Chief, International Rulings Group, Office of the Assistant Commissioner (Technical), Internal Revenue Service

Professional Activities & Affiliations

Other Professional Affiliations

Member and Past President, Executive Committee, International Fiscal Association

Founder and Chair, Transfer Pricing Discussion Group

Former Chairman, International Taxation Committee, American Bar Association, Business Law Division

Member, Washington International Tax Study Group

Newsroom & Publications

Publications & Alerts
  • Do Theories Trump Facts Under the U.S. Arm's Length Standard? Is the BEPS Pricing Guidance on Intangibles Consistent with the U.S. Law?, BNA Tax Management Transfer Pricing Report, March 17, 2016
  • Tax Court Decision in Altera Overturns Important Transfer Pricing Regulations, The National Law Review, October 2, 2015
  • Transfer Pricing Discussion Group ("TPDG") Comments on Organisation for Economic Co-Operation ("OECD") BEPS Initiatives on Transfer Pricing, Tax Notes Today: Special Report, June 30, 2015
  • TPDG Comments on OECD Discussion Draft on Transfer Pricing Documentation and CbC Reporting, March 10, 2014
  • "CHAPTER 5: Comparable Uncontrolled Price (CUP) Method," Practical Guide to U.S. Transfer Pricing, December 15, 2006
  • "The Attribution of Profits to Permanent Establishments, Report of the United States Branch of the IFA," Cahiers de Droit Fiscal International, Volume 91b, January 1, 2006
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