Richard Slowinski is a Partner in Baker McKenzie's Washington, DC office, which was awarded Band 1 or Tier 1 recognition by Chambers, International Tax Review and other ranking firms. With more than 25 years of experience, he advises clients regarding tax matters, with a focus on transfer pricing. He counsels companies in the transportation, finance, hospitality, electronics, aerospace, e-commerce, pharmaceutical, retail and other industries. His experience with tax controversy and planning includes all phases of administrative dispute resolution and advance pricing agreements (APAs). Richard has served in Baker McKenzie leadership positions, including as Chair of the Washington Office Tax Practice, a member of the North American Transfer Pricing Steering Committee and the Washington Office Hiring Partner. He worked for one year in Baker McKenzie Tokyo.
Representative matters include:
- Obtained unilateral and bilateral APAs involving the IRS and other tax authorities.
- Resolved novel transfer pricing issues such as using foreign company segment data as the tested party for an APA, marketing intangibles, intangible property migration, foreign currency fluctuations, financing transactions, guarantees, plant start-up and shut-down situations, US domestic transfer pricing and customs implications.
- Secured competent authority agreements to eliminate double taxation involving the US, Canada, Japan, Mexico, the United Kingdom, etc.
- Advised numerous companies regarding supply chain restructurings involving Europe, Asia and the Americas.
- Counseled pharmaceutical company on strategies to address transfer pricing risks and reduce taxable permanent establishment concerns.
- Advised companies regarding tax and customs implications of cross-border transactions.
Richard has authored articles and given speeches sponsored by the ABA, Bloomberg/BNA, EEI, FBA, IFA, Japan Tax Association, OFII, TEI and other professional organizations. He co-chairs the FBA Tax Law Conference (International Tax) (since 2013). Selected recent presentations include:
- "Strategies for Managing Global Transfer Pricing and APAs," OFII, Palm Beach
- "New World for Resolving Transfer Pricing Disputes," FBA, Washington, DC
- "US Tax Reform & Transfer Pricing Developments," Japan Tax Association, Tokyo
- "Intersection of Transfer Pricing and Customs Valuations: Opportunities & Challenges," Transfer Pricing Conference, Washington, DC
- "Changing Face of International Tax Challenges," TEI, Washington, DC
- "Transfer Pricing: Enforcement & BEPS Developments," Washington, DC
Bar admissions include Maryland Bar, District of Columbia Bar and United States Tax Court. He received an LL.M. in Taxation from Georgetown University Law Center, a J.D. from Catholic University of America, and a B.A. from Bucknell University.