WASHINGTON, DC — McDermott Will & Emery is pleased to announce that on February 27, 2004, Steven Hannes, a tax partner in the Firm’s Washington, D.C. office, was elected as Executive Vice President of the U.S.A. Branch of the International Fiscal Association (IFA). His term as the Executive Vice President will last until February 2006, at which point he will, under the IFA bylaws, automatically become the President of the U.S.A. Branch until February 2008.
The U.S.A. Branch of IFA has approximately 1,000 members and is the largest branch of the worldwide IFA organization which, in total, has approximately 10,000 members resident in over 90 countries. IFA is recognized in the United States and many other countries as the premier professional organization for those interested in matters of international taxation. IFA’s membership is diverse and consists of persons who work in tax departments of multinational corporations and in law and accounting firms, as well as academics and government officials.
Mr. Hannes has been a member of the Executive Committee of the U.S.A. Branch of the IFA and, prior to his election as Executive Vice President, he was the IFA Vice President for the Washington, D.C. region.
Mr. Hannes’ international tax practice at McDermott Will & Emery encompasses 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 recently successfully concluded the settlement of cross-border transfer pricing and other issues for a foreign-based 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 Audit, Appeals, Competent Authority and the Advance Pricing Agreement office.
Mr. Hannes is nationally recognized for his work on cross-border corporate structures and transactions and, in particular, in 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 non-durable goods, such as beverages and photo equipment, among others.
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. A recent article, which 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, appeared in Tax Notes.
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.
Mr. Hannes received his bachelor’s degree from Amherst College in 1967 and his juris doctor degree from New York University School of Law in 1970. He is a member of the District of Columbia bar.