Overview
Philip (Phil) J. Levine focuses his practice on domestic and international corporate tax issues related to reorganizations, spin-offs, acquisitions and dispositions, and consolidated returns matters. He speaks frequently on these issues at seminars sponsored by bar associations and other organizations.
Previously, Phil served as deputy associate chief counsel and as assistant chief counsel of the Corporate Division of the Office of Chief Counsel of the Internal Revenue Service (IRS), where he was responsible for determining the organization’s position with respect to virtually all significant regulations, rulings, legislation and tax controversies on audit and in litigation relating to corporate taxation. He also selected corporate tax projects for inclusion on the annual Guidance Priorities List. In addition, he served as principal spokesperson for the IRS in meetings and public hearings regarding corporate tax issues.
Results
Phil has played a leading role on behalf of his clients in a wide variety of matters, including representing:
- A large multinational corporation in connection with a worldwide restructuring following a $20 billion acquisition
- A large multinational corporation in connection with a restructuring of its Eastern European and Asian operations
- A large multinational corporation in connection with a restructuring of its ownership of its intellectual property
- A technology corporation in obtaining a multibillion-dollar tax refund from the IRS
- Multiple clients in connection with major public spin-offs
Recognitions
- The Best Lawyers in America 2013 to 2023,Tax Law
- The Legal 500 US 2017
Community
- American Bar Association, officer of the Corporate Tax Committee
- District of Columbia Bar Association
Credentials
Education
State University of New York – Buffalo Law School, JD, 1974
New York University School of Law, LLM, 1980
Clark University, BA, 1971
Admissions
District of Columbia
New York
Courts / Agencies
US Court of Appeals for the Second Circuit
US District Court for the Eastern District of New York
US District Court for the Southern District of New York
US Tax Court
Languages
English
