Contact
P (202) 568-6377
F (202) 568-6277
zlevi@dlpatlaw.com
- LL.M., Master in Law (Taxation), 1996, New York University (NYU) School of Law
- J.D., cum laude, 1995, Brooklyn Law School
- Articles Editor, Brooklyn Journal of International Law
- B.A., magna cum laude, 1992, Fordham University
- Alpha Sigma Lambda Honor Society
- New York
- District of Columbia
- U.S. Tax Court
- The Tax Cuts and Jobs Act -- What Every Business Lawyer Needs to Know about International Tax, American Bar Association (ABA), Business Law Section (CLE - 5/22/2018)
- The Changing Landscape of Transfer Pricing in the U.S. Explored, The Knowledge Group (CLE/CPE - 04/10/2018)
- Remarkable Developments to IRS Advance Pricing Agreement Process: What Lies Ahead in 2016 and Beyond, The Knowledge Group (CLE/CPE - 09/29/2016)
- Tax Considerations for Expats, InterNations, DC chapter (2014)
- U.S. Transfer Pricing - The View From The Trenches, IIR Int'l Transfer Pricing Summit (UK, 2003)
- Transfer Pricing: Alternative Practical Strategies, 890 BNA Tax Management Portfolios, Cost Sharing Arrangements, October 2007
- Procedural Rules for Claiming Set-offs Continue to Emphasize the Importance of Maintaining Contemporaneous Documentation, Vol. 83, No. 10, Taxes-The Tax Magazine 53, October 2005; (Republished on the Social Science Research Network’s eLibrary, December 2005)
- Exploring the Implications of State Formless Conversions After Rev. Rul. 2004-59, 82 Taxes-The Tax Magazine 51, September 2004
- Are All Things Royal in Royalties? A Comparison Between Two Treaties, 32 Tax Notes Int’l 1015, December 15, 2003
- Ninth Circuit Grapples With Marketing Intangibles, Overturns Tax Court in DHL Inc. v. Commissioner, 41 Tax Management 427, October 2002
- The Financial Products Provisions of the Taxpayer Relief Act of 1997, Tax Management Memo 2-295, November 1997
Bittker & Lokken, Fundamentals of International Taxation (Thomson Reuters/WG&L, 2013/2014 ed.), ¶79.12, n. 27;
Bittker & Eustice, Federal Income Taxation of Corporations and Shareholders (Thomson Reuters/WG&L, 7th ed. 2000 & Supp. 2014-3), ¶2.02, n. 56; ¶3.18, n378;
Bittker & Lokken, Federal Taxation of Income, Estates and Gifts (Thomson Reuters/Tax & Accounting, 2d/3d ed. 1993-2014, 2013 & 2014 Cum. Supp. No. 3), ¶79.12, n 27.
- IRS Reminds Taxpayers With Foreign Financial Assets of FBAR/FATCA Obligations, 25 CCH Federal Tax Weekly 294, June 18, 2015
- Tough choice for Bank Leumi US Customers, Globes, January 12, 2015
- U.S tax authority targets Israeli investment funds, Globes, November 18-19, 2014
- More Israelis look to give up U.S. citizenship, Globes, April 29, 2010
- Tax Experts Give Insights About New Manufacturing Deduction Regs, 22 CCH Federal Tax Weekly 255, June 1, 2006
American Bar Association (ABA)
Section of Taxation
- Affiliated and related corporations committee
- Banking & Savings Institutions Committee
- Civil and Criminal Tax Penalties Committee
- Foreign Activities of U.S. Taxpayers Committee
- Transfer Pricing Committee
- U.S. Activities of Foreigners & Tax Treaties Committee
Business Law Section
- Taxation Committee
- White Collar Crime Committee
- Partner, Chair International Tax Practice Group, Womble Carlyle Sandridge & Rice PLLC, 2005-2011
- Of Counsel, Powell Goldstein LLP, 2003-2005
- Counsel, Miller & Chevalier Chartered, 1997-2003
- Associate, Piper & Marbury LLP, 1996-1997
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.
- Representing a publicly traded multinational conglomerate in an IRS examination involving domestic and international tax issues.
- Representing a domestic Subchapter S corporation engaged in e-commerce in an IRS audit involving payments of royalties to licensees worldwide.
- Representing a multinational enterprise before the IRS Office of Appeals in connection with proposed transfer pricing adjustments worth millions of dollars.
- Representing a U.S. based producer of commodities before the IRS Office of Appeals in connection with proposed disallowance of certain charges and the attempted recharacterization of transactions.
- Securing an APA for a foreign-based financial institution in connection with controlled foreign exchange (FX) spot and FX forward contracts transactions.
- Obtaining Competent Authority relief from double taxation for a U.S.-based semi-conductor corporation with respect to withholding taxes on royalties received from sources outside the United States.
- Structuring, documenting and implementing transfer pricing policies (including preparation of contemporaneous documentation) for a foreign-based MNE in connection with cross services transactions and the transfer of trademarks and other intangible assets.
- Structuring, documenting and implementing transfer pricing policies (including preparation of contemporaneous documentation) for a tax exempt foundation relating to transactions with a wholly-owned for-profit subsidiary.
- Structuring and negotiating the acquisition of a multinational electronics manufacturing and distribution group of companies with operations in the Far East, United States and Europe.
- Successfully representing taxpayers in OVDP before the IRS CID.