Zion_web[1]
Contact
P (202) 568-6377
F (202) 568-6277
zlevi@dlpatlaw.com

Education
  • 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
Admitted to the Bar
  • New York: 1996
  • District of Columbia: 1998
Selected Publications
  • 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
Professional Activities

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
In Books and Treatises

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.

In The News
  • 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
Prior Legal Experience
  • 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

As an accomplished tax attorney, Zion Levi serves as legal advisor and counselor to clients dealing with tax controversies, international and domestic business tax, and criminal tax matters.

In the area of tax controversy, Zion represents clients during IRS audits (including alternative dispute resolution proceedings), and renders strategic support to clients undergoing examinations by foreign taxing authorities. He also advocates against unwarranted adjustments before the IRS Office of Appeals as well as the U.S. Tax Court, and has a strong record of securing favorable settlements in substantial client disputes.

As one of the nation’s leading transfer pricing lawyers, Zion counsels clients on matters such as establishing and implementing transfer pricing policies, ascertaining arm’s length prices and related intercompany arrangements, preparing related-party agreements and other contemporaneous documentation, and obtaining expert economic analyses—which serve to demonstrate the sophistication and complexity of matters he handles. Being based in Washington, DC, he has frequent contact with IRS officials and leverages that experience for both U.S. and international clients in negotiating and closing Advance Pricing Agreements (APAs), securing competent authority relief, obtaining Simultaneous Appeals Procedure (SAP) reviews, and procuring favorable Private Letter Rulings (PLRs).

Zion’s business acumen proves valuable when strategizing and planning optimal international structures (both inbound and outbound), purchasing or selling commercial real property, and in negotiating complex cross-border transactions. On related matters, he advises on international hybrid structures, bilateral tax treaties, permanent establishments, branch profit tax, controlled foreign corporations (CFCs), Real Estate Investment Trusts (REITs), and passive foreign investment companies (PFICs).

In his capacity as a sought-after tax attorney, Zion is called upon to interact with Special Agents in Charge and other agents at the IRS Criminal Investigation Division while representing clients in sensitive criminal tax matters. He counsels on alternative legal options that may be available to taxpayers, including whether they may qualify for any of the IRS voluntary disclosure and compliance programs such as the domestic voluntary disclosure program, the offshore voluntary disclosure program, and the streamlined filing compliance procedures. Zion also represents clients in matters before the Federal Bureau of Investigation, the Department of Homeland Security, the U.S. Immigration and Customs Enforcement, and the U.S. Department of State.

Zion draws upon more than 20 years of legal experience, including as a partner and international tax practice group leader with a national law firm, in representing clients in virtually every domestic and international industry vertical. He is a contributor to the Bureau of National Affairs (BNA), has published extensively in respected industry and professional publications, and has had his work cited in authoritative legal tax treatises.

Recent Engagements
  • 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.