Mark P. Thomas, PC, advises clients on all aspects of taxation, including complex civil tax controversies and litigation, transfer pricing, and domestic and international tax planning issues.

Mark has extensive transfer pricing planning, compliance, and dispute resolution experience in a broad array of industries that include manufacturing, pharma, entertainment and technology, retail and distribution, food and beverage, and financial services. He also has significant experience in structuring advance pricing agreements on a global basis. A substantial portion of Mark’s practice is devoted to handling the myriad valuation issues associated with mergers, acquisitions, divestitures and other transfers that often have significant tax and transfer pricing implications.

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  • Currently representing numerous multinational companies in connection with transfer pricing examinations focusing on sourcing activities
  • Currently representing high profile taxpayers in Tax Court in connection with IRS efforts to convert capital gain from the sale of an investment management company into more than $250 million of ordinary income
  • Currently representing multinational company in connection with IRS attempts to reclassify billions of debt as equity

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  • Chambers USA 2019
  • The Legal 500 US 2016 – 2019
  • World Tax, International Tax Review 2016 – 2018


New York University School of Law, LLM, 1998
University of Idaho College of Law, JD, 1997
University of Idaho, BS, summa cum laude, 1994


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Mark P. Thomas, PC

Insights & Events / Media

Chicago, IL / McDermott Event / May 8, 2019

Chicago, Illinois / McDermott Event / September 27, 2018

Journal of Corporate Taxation / March/April 2018

International Transfer Pricing Journal / February 26, 2018

Chicago, Illinois / McDermott Event / November 16, 2017

Houston, Texas / McDermott Event / November 2, 2017

Tax Notes / Worldwide Tax Daily / March 21, 2016

Tax Notes / Worldwide Tax Daily / December 23, 2015

Tax Executives Institute / September/October 2015