Global Tax 50 2015: Paige Marvel

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Global Tax 50 2015: Paige Marvel

Judge, US Tax Court

Paige Marvel

Paige Marvel is a new entry this year

Transfer pricing litigation does not get to trial often. It is a complex affair that usually demands lengthy preparation – read, expense – and numerous participants, often in the form of expert witnesses – read, more expense. And there is the feeling that taxpayers would prefer if they did not have to explain publicly how they worked out their related-party policies. So practitioners everywhere were waiting for the rarity that was Paige Marvel's US Tax Court decision in Altera last July.

Marvel ruled the Treasury and Internal Revenue Service's disregard for the Administrative Procedure Act meant that the regulation, introduced after the government lost the Xilinx case in 2005 – a decision affirmed by the appeals court in 2010 – that the value of stock-based compensation had to be included in a cost-sharing agreement was invalid. Altera had argued that the regulation was based on something that had already been rejected in Xilinx because it was not deemed to be arm's-length.

Marvel has been on the court for almost 18 years, having been appointed by President Clinton in 1998 after a decade as a partner of Venable. President Obama reappointed her to another 15 year term in 2014. She may not deliver a more significant judgment than in Altera.

The Global Tax 50 2015

View the full list and introduction

The top 10 • Ranked in order of influence

1. Margrethe Vestager

2. Pascal Saint-Amans

3. Wang Jun

4. Arun Jaitley

5. Marissa Mayer

6. Will Morris

7. Ian Read

8. Pierre Moscovici

9. Donato Raponi

10. Global Alliance for Tax Justice

The remaining 40 • In alphabetic order

Brigitte Alepin

Andrus Ansip

Tamara Ashford

Mohammed Amine Baina

Piet Battiau

Elise Bean

Monica Bhatia

David Bradbury

Winnie Byanyima

Mauricio Cardenas

Allison Christians

Rita de la Feria

Marlies de Ruiter

Judith Freedman

Meg Hillier

Vanessa Houlder

Kim Jacinto-Henares

Eva Joly

Chris Jordan

Jean-Claude Juncker

Alain Lamassoure

Juliane Kokott

Armando Lara Yaffar

Liao Tizhong

Paige Marvel

Angela Merkel

Zach Mider

Richard Murphy

George Osborne

Achim Pross

Akhilesh Ranjan

Alan Robertson

Paul Ryan

Tove Maria Ryding

Magdalena Sepulveda Carmona

Lee Sheppard

Parthasarathi Shome

Robert Stack

Mike Williams

Ya-wen Yang

more across site & shared bottom lb ros

More from across our site

The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted
The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
The global minimum tax deal is not viable without US participation, Friedrich Merz has argued
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut
The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year
Gift this article