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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

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