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. He is a former official at the Department of the Treasury and delegate to the Organisation for Economic Cooperation and Development (OECD), bringing this perspective to bear when advising clients. Mr. Femia has been recognized as one of the country's leading international tax practitioners in publications such as Chambers USA and The Best Lawyers® in America, for over a decade, described in Chambers USA as "a great lawyer, great on the transfer pricing side, and provid[ing] guidance and help with policy matters that is second to none" and a "superstar." 

Mr. Femia's practice focuses on counseling and advocacy work on behalf of U.S.- and foreign-based multinational enterprises across multiple industries. 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 counsels clients with respect to the implications of international tax developments and enforcement initiatives – including Pillar 2 minimum taxes being considered around the world – on cross-border supply chain, intangible holding, and financing structures. This work has included advice related to restructuring or other planning to avoid inappropriate results and engagement with policymakers. His transfer pricing work includes advisory work related to new business arrangements and transfers of intangible property, the negotiation of advance pricing agreements (APAs) with the IRS and other tax authorities, the resolution of disputes through the competent authority or Mutual Agreement Procedure (MAP) process, and the resolution of disputes with the IRS through the administrative Appeals process and litigation. Mr. Femia has led large teams of attorneys and other professionals in executing these matters, drawing on a pool of talented personnel at Miller & Chevalier and working together with client resources to achieve remarkable results.