Steven Hannes is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Washington, D.C., office. Mr. Hannes has been recognized in the Legal 500; named “Best of the Best” tax advisors for transfer pricing in surveys by Euromoney; listed in Woodward/White's The Best Lawyers in America in the specialty of Tax Law and Litigation and Controversy-Tax Law, recognized in The International Who’s Who of Corporate Tax Lawyers and The International Who's Who of Business Lawyers; and U.S. News has included Mr. Hannes in its best list for the Tax Law category.
Mr. Hannes focuses his practice on advising U.S. and foreign based multinational corporations on developing their cross-border transactions, as well as representing multinationals in tax controversies. He is nationally recognized for, in particular, creating and defending structures and contractual arrangements that involve intra-group transactions and prices for intellectual property, goods and services. Mr. Hannes has dealt with companies in, among other 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. He works on matters at IRS Audit, Appeals, Competent Authority and the Advance Pricing Agreement office.
Mr. Hannes founded 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 on the Executive Committee of the IFA U.S.A. Branch. 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 international and national conferences, Mr. Hannes has also authored many articles on international tax topics. One notable article analyzes whether “de-risked” U.S. distributors or U.S. service providers can create U.S. permanent establishment risks for their foreign counterparties. Mr. Hannes prepared the U.S.A. National Report on the subject of attributing profits to permanent establishments for the 2006 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. He helped negotiate income tax treaties and protocols with, among others, the governments of Canada, and the United Kingdom. Before joining Treasury, he was chief of the international rulings group in what was then called the Office of the Assistant Commissioner (Technical) of the IRS.
J.D., New York University School of Law (1970)
B.A., Amherst College (1967)
Steven P. Hannes is a member of the Bloomberg BNA Tax Management Transfer Pricing Advisory Board.
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