Rocco Femia

Rocco V. Femia’s practice focuses on international tax planning for domestic and foreign-based enterprises, and on assisting such enterprises in avoiding or resolving controversies with the Internal Revenue Service and foreign tax authorities involving U.S. international tax rules, transfer pricing, and U.S. tax treaties.  Mr. Femia has represented taxpayers before the Internal Revenue Service, the U.S. Department of the Treasury, the Joint Committee on Taxation, and the staffs of the House Ways and Means Committee and the Senate Finance Committee. Mr. Femia is a former Associate International Tax Counsel at the U.S. Department of the Treasury, Office of Tax Policy.  While at the Treasury, Mr. Femia had responsibility for a broad spectrum of U.S. tax treaty and international tax regulatory and legislative matters.  Mr. Femia was the principal staff attorney involved in the negotiation of the 2003 U.S.-Japan tax treaty, and had responsibility for regulatory and other guidance in the areas of intercompany transfer pricing, subpart F, and check-the-box.  He advised senior officials on pending legislation regarding U.S. international taxation, including the 2003 Jobs and Growth Revenue Reconciliation Act and the 2004 American Jobs Creation Act.  Mr. Femia also represented the interests of the United States in international organizations, including the Organization for Economic Cooperation and Development Committee on Fiscal Affairs. Prior to joining the Treasury in 2000, Mr. Femia practiced at Miller & Chevalier as a tax associate. Mr. Femia graduated, magna cum laude, from Georgetown University Law Center in 1995.  He received his B.A. in Economics from Duke University in 1991. Rocco Femia was quoted in BNA Transfer Pricing Report on the IRS policy encouraging taxpayers to exhaust remedies in a foreign country, including through litigation, before seeking to credit foreign taxes against U.S. tax liability. Rocco Femia discusses the outbound transfer of IP with a Treasury official at an AICPA conference on January 10.