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Global Tax 50 2015: Paige Marvel

02 February 2016

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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

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