| Rocco Femia represents large, multinational corporate clients in high-stakes U.S. international tax policy, planning, and controversy matters. Over his 15 plus years in practice, Mr. Femia has assisted large multinational clients in evaluating and minimizing the tax costs of international business operations and investments and in resolving U.S. and international tax disputes. 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 and 2011, and one of The Best Lawyers in America from 2009 to 2012. More > Rocco Femia represents large, multinational corporate clients in high-stakes U.S. international tax policy, planning, and controversy matters. Over his 15 plus years in practice, Mr. Femia has assisted large multinational clients in evaluating and minimizing the tax costs of international business operations and investments and in resolving U.S. and international tax disputes. 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 and 2011, and one of The Best Lawyers in America from 2009 to 2012.
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 been entrusted by significant multinational enterprises to advise them on high-stakes and complex matters. Mr. Femia routinely counsels clients with respect to transfer pricing matters, including the negotiation of Advance Pricing Agreements with the IRS and other tax authorities as well as the resolution of disputes through the Competent Authority or MAP process. Mr. Femia often counsels 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 represents clients before the IRS in the context of disputes, and before the U.S. Treasury Department and the tax writing committees of the Congress on regulatory, legislative, and other policy matters.
Mr. Femia is a former Associate International Tax Counsel at the U.S. Department of the Treasury, Office of Tax Policy. While at the Treasury from 2000 to 2004, Mr. Femia had responsibility for a broad spectrum of U.S. tax treaty and international tax regulatory and legislative matters. He was the principal staff lawyer involved in the negotiation of the 2003 U.S.-Japan Tax Treaty, and had responsibility for regulatory and other guidance including seminal transfer pricing guidance related to services transactions and the transfer of intangibles. He advised senior officials on pending legislation regarding U.S. international taxation, including significant legislation in 2003 and 2004. Mr. Femia also represented the interests of the United States in international organizations, including the OECD's Committee on Fiscal Affairs and Global Forum.
Mr. Femia is a former Adjunct Professor at the Georgetown University Law Center. Mr. Femia often is quoted in the tax press and regularly publishes articles and other publications on timely tax issues. He is the author of a chapter on services transactions in a leading transfer pricing treatise published by LexisNexis. In addition, he is a contributing author to The Transfer Pricing Answer Book 2012. Mr. Femia is a sought-after panelist and speaker on transfer pricing, tax treaty, and international tax issues.
Mr. Femia is a member of the International Fiscal Association, the American Bar Association, and the D.C. Bar Association. He is ranked in Chambers USA, Best Lawyers in America, and Legal 500. < Brief Bio
- Counseling with respect to Advance Pricing Agreements involving among other items the allocation of head office expenses.
- Counseling and advocacy with respect to a transfer pricing dispute related to the cross-border provision of services and involving hundreds of millions of dollars of proposed adjustments.
- 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.
- Counseling and advocacy with respect to an interest expense allocation dispute involving tens of millions of dollars of proposed adjustments.
Government Experience
- Associate International Tax Counsel, U.S. Department of the Treasury, 2003 - 2004
- Attorney Advisor, U.S. Department of the Treasury, 2000 - 2003
Rankings and Recognition
- Chambers USA: Tax (District of Columbia), 2010 - 2011
- The Best Lawyers in America®: Litigation & Controversy - Tax and Tax Law, 2009 - 2012
- Legal 500: Tax: Tax Controversy, 2010 - 2011
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; Vice Chair, International Tax Committee
- Former Adjunct Professor, Georgetown University Law Center
Education - J.D., Georgetown University Law Center, magna cum laude, 1995
- B.A., Duke University, 1991
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