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Experience:
Patricia Anne Rexford is a tax controversy and litigation attorney. She represents taxpayers at all stages of tax controversies, including audit, IRS administrative appeals, trial, and appellate court review, including the US Supreme Court.
Tricia's experience encompasses Section 482 transfer pricing and cost sharing issues; DISC, FSC and ETI issues; Subpart F issues (foreign base company income, shipping income, and section 956 "banking exception"); substance-over-form issues; tax-free reorganizations; entitlement to Brazilian foreign tax credits; foreign-source income on export sales; proper treatment of construction allowances; summons enforcement; and penalties.
Prior to joining Mayer Brown in 1993, Tricia served as a Special Intern with the Foreign Affairs Department of the Kanagawa Prefectural Government in Yokohama, Japan (1989-1990). She is fluent or proficient in Spanish, Japanese, Italian and French.
Notable Engagements:
PNC Financial Services Group, Inc. v. C.I.R., --- F.3d ----, 2007 WL 2403550, (D.C.Cir. Aug 24, 2007), affirming Riggs National Corp. v. Commissioner, T.C. Memo. 2004-110, 87 T.C.M. (CCH) 1276 (2004) ("Riggs III"), on remand from 295 F.3d 16 (D.C. Cir. 2002), rev'g and remanding T. C. Memo. 2001-12, 81 T.C.M. (CCH) 1023 (2001) ("Riggs II"), on remand from 163 F.3d 1363 (D.C. Cir. 1999), rev'g and remanding 107 T.C. 301 (1996) ("Riggs I"); holding that official tax receipts of Brazilian government were entitled to evidentiary presumption and addressing effect on foreign tax credits of subsidy paid to governmental entity.
Tribune Company v. Commissioner of Internal Revenue, 125 T.C. 110 (2005); holding that the divestiture of Bender was a taxable sale and not a tax-free reorganization; settled pending appeal in the Seventh Circuit.
The Boeing Company and Consolidated Subsidiaries v. United States of America, 123 S.Ct. 1099 (2003); allocation of R&D costs in determination of sales income under DISC and FSC rules.
The Limited, Inc. v. Commissioner of Internal Revenue, 286 F.3d 324 (6th Cir. 2002), rev'g, 113 T.C. 169 (1999); reversing the Tax Court's holding that a CFC's purchase of CDs from an affiliated credit card bank failed to qualify as §956(c)(2)(A) "deposits with persons carrying on the banking business."
Intel Corporation v. Commissioner of Internal Revenue, 76 F.3d 976 (9th Cir. 1995); allocation of income partly from sources within a foreign country under Treas. Reg. §1.863-3(b)(2).
Nissei Sangyo America, Ltd. v. United States, 95-2 US Tax Cas. (CCH) 50,327 (N.D. Ill. 1995); Section 6038A summons case; IRS motion denied.
Education:
University of Chicago Law School, JD, with honors, 1993; Order of the Coif; Comment Editor, University of Chicago Law School Roundtable, Harvard College, BA, cum laude, 1989; Dean's List; John Harvard Scholarship. | 