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Rocco V. Femia

Rocco Femia represents large, multinational corporate clients in high-stakes U.S. international tax and transfer pricing planning, controversy, and policy matters. Mr. Femia is a former official at the U.S. Department of the Treasury and delegate to the OECD, and brings this perspective to bear in advising clients. Mr. Femia was named one of the country’s leading practitioners in the field of taxation by Chambers USA: America’s Leading Lawyers for Business 2010 to 2013, and one of the Best Lawyers in America® from 2009 to 2016. Clients quoted by Chambers have said that Mr. Femia is noted for his "great reputation as an international planner."

Mr. Femia's practice focuses on counseling and advocacy work on behalf of U.S. and foreign-based multinational enterprises. These projects typically involve complex, highly technical U.S. international tax, tax treaty, and transfer pricing issues often involving hundreds of millions or billions of dollars. Mr. Femia has counseled clients with respect to the U.S. international tax consequences of their cross-border business operations, including issues involving supply chain planning, funding arrangements and cash management (including repatriation). Mr. Femia’s transfer pricing work has included the negotiation of Advance Pricing Agreements with the IRS and other tax authorities, the resolution of disputes through the Competent Authority or MAP process and the resolution of disputes with the IRS through the administrative Appeals process and litigation.

Representative Engagements|View All

  • Counseling with respect to Advance Pricing Agreements involving among other items the allocation of head office expenses.
  • Counseling and advocacy related to numerous requests for relief from double taxation by the U.S. Competent Authority under U.S. tax treaties, including matters involving transfer pricing and limitation on benefits issues.
  • Counseling U.S. multinationals on the U.S. tax implications of their cross-border supply chains.
  • Representing foreign-based multinationals on legislative policy matters with respect to pending international tax legislation.
Government Experience
  • Associate International Tax Counsel, U.S. Department of the Treasury, 2003 - 2004
  • Attorney Advisor, U.S. Department of the Treasury, 2000 - 2003
Corporate Experience
Rankings and Recognition
  • Chambers USA: Tax (District of Columbia), 2010 - 2016
  • The Best Lawyers in America®:  Litigation & Controversy - Tax and Tax Law, 2009 - 2017
  • Legal 500: Tax: International Tax, 2013 - 2016
  • Legal 500: Tax: Tax Controversy, 2010 - 2012, 2014 - 2015 
Professional and Community Involvement
  • Member, International Fiscal Association; Member, Council of the DC Region of IFA
  • Member, Section of Taxation, American Bar Association
  • Member, Taxation Section, District of Columbia Bar; Chair, International Tax Committee
  • Former Adjunct Professor, Georgetown University Law Center
Bar Admissions
  • District of Columbia
Court Admissions
Clerkships
Foreign Languages
Education
  • J.D., Georgetown University Law Center, magna cum laude, 1995
  • B.A., Duke University, 1991