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Steven P. Hannes is a partner in the law firm of McDermott Will & Emery LLP based in the Washington, D.C. office. Mr. Hannes was named "Best of the Best" tax advisors for transfer pricing in surveys by Euromoney in 2001and 2008. He is also in Woodward/White's The Best Lawyers in America (2006-2008), in the specialty of tax law.
As a member of the McDermott Tax Department, Mr. Hannes focuses on advising U.S. and foreign based multinational corporations on structuring their cross-border transactions, as well as representing multinationals in tax controversies. For example, he successfully concluded the settlement of cross-border transfer pricing and other issues for a multinational for a period of 15 tax years. In order to bring this complex situation, with large asserted tax liabilities, to a successful close, Mr. Hannes represented the client at IRS Audit, Appeals, Competent Authority and the Advance Pricing Agreement office.
Mr. Hannes is nationally recognized for, in particular, developing and defending structures and contractual arrangements that involve intercompany prices for intellectual property, goods and services. Mr. Hannes has dealt with companies in diverse industries, including automotive; heavy machinery; pharmaceuticals and chemicals; computer and electronics; research, technical and other services; and consumer goods, such as beverages and photo equipment, among others.
Mr. Hannes started and chairs the Transfer Pricing Discussion Group, which consists of U.S. and foreign-based multinationals who meet regularly to discuss transfer pricing and related matters.
Mr. Hannes was president of the U.S.A. Branch of the International Fiscal Association (IFA) from 2006 until March 2008. He is now President Emeritus of the IFA USA Branch. He is on Tax Management's advisory board on Transfer Pricing and the editorial advisory board of the Journal of International Taxation. He is a member of the Washington International Tax Study Group. He is a former chairman of the International Taxation Committee of the Business Law Division of the American Bar Association (1987).
A frequent speaker at national and local conferences and courses on international taxation matters, Mr. Hannes has also authored many articles on international tax topics, including foreign tax credit planning and handling transfer pricing audits. One notable article analyzed in detail whether "de-risked" U.S. distributors or U.S. service providers can create U.S. permanent establishment risks for their foreign counterparties; it appeared in Tax Notes. Mr. Hannes prepared the USA National Report on the subject of attributing profits to permanent establishments for the 2006 Amsterdam Congress of IFA.
Prior to entering private practice in 1982, Mr. Hannes was the associate international tax counsel in the Office of the Assistant Secretary (tax policy) of the U.S. Department of the Treasury. In this capacity he helped negotiate income tax treaties and protocols with, among others, the governments of Canada, Cyprus, Germany, Jamaica, Norway and the United Kingdom. Before joining the Treasury, he was chief of the international rulings group in what was then called the Office of the Assistant Commissioner (technical) of the IRS.
Education:
New York University School of Law, J.D., 1970
Amherst College, B.A., 1967 | 