Contact
P (202) 568-6377
F (202) 568-6277
zlevi@dlpatlaw.com

Zion Levi

Washington, DC

Zion Levi is a highly skilled and experienced tax, business transactions and real estate attorney and seasoned legal advisor to domestic and international businesses and business owners.

Mr. Levi’s tax practice encompasses all facets of federal income tax law and related state income taxation, with a particular focus on tax controversies, tax planning and international taxation.  He has substantial expertise in representing clients during IRS audits and other examinations, at the IRS Office of Appeals, the IRS Advance Pricing Mutual Agreement (APMA) Program, the IRS Criminal Investigation Division (CID) and before the United States Tax Court.  Mr. Levi specializes in strategizing and planning efficient international structures (both inbound and outbound) and regularly counsels clients on domestic and international matters such as treaty-based positions, e-commerce, permanent establishments, methods of accounting, transfer pricing, like-kind exchanges under IRC 1031, depreciation and amortization, branch profit tax, hybrid structures, cryptocurrency, specialized voluntary disclosures, mergers, acquisitions and other reorganizations (M&As), consolidated tax returns, foreign tax credits, transfer of intangible property (IP), personal goodwill, allocation of purchase price, controlled foreign corporations (CFCs), passive foreign investment companies (PFICs), Foreign Derived Intangible Income (FDII), Global Intangible Low-Tax Income (GILTI), and Base Erosion and Anti-Abuse Tax (BEAT).

In the area of business transactions, Mr. Levi’s acumen proves highly valuable when strategizing efficient domestic and international acquisition structures, in negotiating complex mergers and other business combinations, in obtaining favorable Private Letter Rulings (PLRs), and in securing Advance Pricing Agreements (APAs) and competent authority relief.  Mr. Levi served as counsel on numerous corporate acquisitions ranging in size from $500 thousand to more than $500 million.

In the area of real estate, Mr. Levi has extensive experience in a wide range of commercial real estate transactions, including the acquisitions and dispositions of commercial buildings, like-kind exchanges under IRC 1031, Real Estate Investment Trusts (REITs), tenancy in commons (TICs), commercial leases, ground leases, joint ventures, and permanent and mezzanine financing.  Mr. Levi has served as lead negotiator on multiple acquisitions and dispositions of commercial buildings of all classes, and has authored tax opinions in the area of like-kind exchange under IRC 1031.

Mr. Levi draws upon more than 24 years of legal experience in representing clients in virtually every domestic and international industry vertical. He is a contributor national expert to the Bureau of National Affairs (BNA), a frequent speaker and panelist in CLE programs, including programs produced and sponsored by the American Bar Association (ABA), has published extensively in respected industry and professional publications, and has had his work cited in authoritative legal treatises.