Zion Levi Esq.

A Partner with Dearson Levi & Pantz, Zion Levi is a highly skilled and experienced tax and transactions attorney, legal advisor and counselor.  Mr. Levi’s practice encompasses all facets of federal income tax law, with a particular focus on tax controversies, international business tax, and criminal tax matters.  In the area of tax controversy, Mr. Levi represents clients effectively during IRS audits, including in alternative dispute resolution (ADR) proceedings. He also persuasively advocates against unwarranted proposed adjustments before the IRS Office of Appeals, having a remarkable record in favorably settling substantial disputes for clients.
Mr. Levi is one of the nation’s leading transfer pricing experts. His Washington, DC base and frequent contacts with IRS officials give him a unique ability to assist U.S. and international clients in obtaining Simultaneous Appeals Procedure (SAP) reviews, negotiating and closing Advance Pricing Agreements (APAs), securing competent authority relief, and procuring favorable Private Letter Rulings (PLRs). He regularly counsels clients on matters such as establishing and implementing transfer pricing policies, ascertaining arm’s length prices and related intercompany arrangements, preparing contemporaneous documentation, and obtaining expert economic analyses.
Mr. Levi is a shrewd business attorney who specializes in strategizing and planning optimal international structures (both inbound and outbound), and in negotiating complex cross-border transactions. He further advises on such matters as international hybrid structures, bilateral tax treaties, permanent establishments, branch profit tax, controlled foreign corporations (CFCs), and passive foreign investment companies (PFICs).
Mr. Levi is an accomplished criminal tax attorney. He regularly interacts with Special Agents in Charge (SACs) and other agents at the IRS Criminal Investigation Division (CID) 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 (OVDP), and the streamlined filing compliance procedures. Mr. Levi has also represented clients in matters before the Federal Bureau of Investigation (FBI), the Department of Homeland Security (DHS), the U.S. Immigration and Customs Enforcement (ICE), and the U.S. Department of State (DOS).

B.A., Fordham University (1992) magna cum laude
J.D., Brooklyn Law School (1995) cum laude
LL.M., Taxation, New York University School of Law (1996)

Bloomberg BNA Tax Management Portfolios:
890 T.M., Transfer Pricing: Alternative Practical Strategies (co-author)