- J.D.Georgetown University Law Centermagna cum laude1995
- B.A.Duke University1991
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 2018, and one of the Best Lawyers in America® from 2009 to 2018. 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.
- 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.
- Associate International Tax Counsel, U.S. Department of the Treasury, 2003 - 2004
- Attorney Advisor, U.S. Department of the Treasury, 2000 - 2003
- Chambers USA: Tax (District of Columbia), 2010 - 2018
- The Best Lawyers in America®: Litigation & Controversy - Tax and Tax Law, 2009 - 2019
- Legal 500: Tax: International Tax, 2013 - 2018
- Legal 500: Tax: Contentious, 2010 - 2012, 2014 - 2015, 2018
- Legal 500: Tax: Non-Contentious, 2018
- Washington's Top Lawyers: Tax (Washingtonian Magazine), 2018
- Washington, DC Super Lawyers®: Tax, 2012 - 2016, 2018
- 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
District of Columbia
Rocco Femia will speak at the TCPI 20th Annual Tax Policy & Practice Symposium on February 14, 2019, in Washington, DC. Femia will moderate the panel, "We Got the BEAT...
Rocco Femia commented on new rules proposed by the U.S. Department of the Treasury that would implement an important part of the Tax Cuts and Jobs Act of 2017.
Washington, DC, November 26, 2018 – Miller & Chevalier Chartered announced today that seven firm Members were named "Top Lawyers" in the December 2018 issue of Washingtonian Magazi
Rocco V. Femia will present during the National Foreign Trade Council's (NFTC) Tax Committee Fall Meeting on October 25, 2018.
Rocco V. Femia and P. Welles Orr spoke during American Petroleum Institute's (API) 2018 Joint Federal Tax Conference on September 18, 2018 in San Diego.
San Diego, CA
On December 13, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 59A, the base erosion and anti-ab
On November 26, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j).1 The 2017 Tax
Last week's Ninth Circuit decision in
In this article, Layla Asali and Rocco Femia discuss Section 367(a) and §3