Phil West

Philip R. West is a partner in the Washington office of Steptoe & Johnson LLP, where he focuses mainly on international tax issues for both domestic and foreign clients. Mr. West also serves on Steptoe's Executive Committee, Strategic Planning Committee, and Diversity Committee. With almost 25 years as a tax lawyer, Mr. West has extensive practical experience minimizing the tax cost of international business operations and transactions. He also devotes significant attention to helping clients favorably resolve difficult matters with the IRS at the National Office, appeals, and exam levels. He has also been particularly active recently with competent authority matters and with attest auditors on FIN 48 and other financial statement issues. Mr. West served for nearly four years as the Treasury Department’s International Tax Counsel, the senior international tax lawyer in the US government. In that position, he played a central role in virtually every policy, legislative, and regulatory development in the international tax area and led tax treaty negotiations, discussions, and ratification efforts involving countries throughout the world. Mr. West also played a major role in the US work at the Organization for Economic Cooperation and Development (OECD) and led official delegations there and on other missions. He has practical experience with many foreign tax systems and good relationships with foreign tax officials and private practitioners around the world. And he is regularly called on to advise government officials with respect to sensitive and complex tax matters. Mr. West has deep substantive knowledge of income deferral, foreign tax credit, transfer pricing, and tax treaty matters, as well as the tax aspects of mergers, acquisitions, joint ventures, and financings, investment funds, and tax minimization structures and transactions. Mr. West also has extensive practical experience dealing with the Treasury Department and Congress on both technical matters and on issues of broad policy significance; and interacting with the IRS and the courts on audits, controversies, and rulings. For his entire professional career, Mr. West has worked on all sides of the tax shelter issue, setting policy on tax shelter issues as a Treasury Department official, litigating tax shelter cases with the Justice Department, advising Judge Carolyn Miller Parr on tax shelter cases as a Tax Court clerk, counseling financial institutions on structured products issues with a Wall Street law firm, evaluating tax shelters and structured products with an international accounting firm, and representing investors and intermediaries while at Steptoe. Mr. West is a frequent speaker and author on international and domestic tax subjects, addressing both professional and academic audiences.