A Duane Webber is a partner and the chair of the Global Tax Practice Group of Baker & McKenzie. He previously served as the chair of Baker & McKenzie's Global Tax Dispute Resolution Group, chair of the North American Tax Practice Group, chair of the Washington Office Tax Group, and managing partner of the firm's Washington DC office.
For more than 30 years, Mr Webber's practice has focused on resolving Federal tax controversies and transfer pricing matters with the IRS and various foreign governments, including all administrative phases of a controversy through litigation in the US Tax Court, various US Courts of Appeal, the US Court of Federal Claims, and the US Supreme Court. Mr Webber has orchestrated the resolution of numerous transfer pricing matters through bilateral and unilateral Advance Pricing Agreements, IRS tax audits, appeals negotiations, fast track appeals, competent authority proceedings, and litigation. The vast majority of the transfer pricing matters on which he has worked were resolved without litigation through the Appeals process, through APAs, or otherwise. Representative transfer pricing litigation cases include Altera Corporation & Subsidiaries v. Commissioner, 145 TC 3 (2015); Bausch & Lomb Incorporated v Commissioner, 92 TC 525, 594 (1989), aff'd, 933 F2d 1084 (2d Cir. 1991); Compaq Computer Corporation v Commissioner, 78 TCM (CCH) 20 (1999); Hewlett-Packard Company v Commissioner, TC Nos 21976-07 & 10075-08; Yamaha Motor Corp (USA) v Commissioner, TC Nos 2674-88 & 26319-88.
In addition to transfer pricing matters, Mr Webber has managed the resolution of a wide variety of domestic and international Federal tax issues, including issues relating to Subpart F income (and the manufacturing test), foreign tax credits, research tax credits, Subchapter L insurance tax, section 892 exempt income, captive insurance, consolidated returns, inventory and tax accounting, asset characterization, and other matters. While most of these disputes were resolved without litigation, representative litigation matters include docketed cases for American International Group, America Online, Apple Computer, Bausch & Lomb Incorporated, The Boeing Company, Borden, CIGNA Corporation, Compaq Computer Corporation, Electronic Arts, Flight Options, Guardian Industries Corp, Linear Technology Corporation, Marsh & McLennan Companies, RadioShack Corporation, Sun Microsystems, Zurich Insurance Company.
Mr Webber has participated in numerous seminars sponsored by TEI, IFA, Georgetown University Law Center, and other organizations. He is a co-author of Transfer Pricing Litigation Strategy and Tactics, Ch 2, BNA Tax Management Portfolio TM 888, and regularly publishes tax controversy and transfer pricing articles in various tax journals and publications.
Mr Webber graduated from Kansas State University (BA, economics and political Science/BS, accounting, cum laude, 1981), and Georgetown University Law Center (1984 JD, magna cum laude). He is member of the J Edgar Murdock American Inn of Court.