Mr. C. David Swenson

To the left of Chairman Grobmyer is Mr. Carlos F. Poza, Deputy Director General USCS Department of Commerce, Mr. David Swenson, Senior Partner of the Baker & McKenzie Law Firm, and Dr. Raj Dwivedy, Senior Economist, U.S. Dept of Commerce.

Washington, D.C., June 24, 2003 - Baker & McKenzie's Washington, DC office announced today that Tax Partners Dennis Meyer, David Swenson and Leonard Terr have been nominated among the world's 30 top transfer pricing lawyers by in-house counsel, corporate clients and other leading tax professionals in a two-year independent study.
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Commenting on the honor, Baker & McKenzie Washington Office Managing Partner Tom Egan said, "We are very pleased that Dennis, David and Len have been recognized for their outstanding abilities, although it comes as no surprise, as they truly represent the best of the best in their field.
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Mr. Swenson currently serves as Chairman of Baker & McKenzie's Washington Office Tax Group and is Chairman of the global Transfer Pricing Practice Group.He has also served as a member of the Baker & McKenzie's Financial Committee and the North American Tax Group Management Committee.

Washington, D.C., June 24, 2003 â€" Baker & McKenzie's Washington, DC office announced today that Tax Partners Dennis Meyer, David Swenson and Leonard Terr have been nominated among the world's 30 top transfer pricing lawyers by in-house counsel, corporate clients and other leading tax professionals in a two-year independent study.
...
Commenting on the honor, Baker & McKenzie Washington Office Managing Partner Tom Egan said, "We are very pleased that Dennis, David and Len have been recognized for their outstanding abilities, although it comes as no surprise, as they truly represent the best of the best in their field.
...
Mr. Swenson currently serves as Chairman of Baker & McKenzie's Washington Office Tax Group and is Chairman of the global Transfer Pricing Practice Group.He has also served as a member of the Baker & McKenzie's Financial Committee and the North American Tax Group Management Committee.

C. David Swenson+1 202 452 7011

C David Swenson
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C David Swenson, BA, JD, MLT, is a partner in the Washington DC office of Baker & McKenzie, and is chairman of the Washington Office Tax Group.Mr Swenson has served as a member of the firm's Worldwide Financial Committee, the North American Tax Group Management Committee and is chairman of the Transfer Pricing Practice Group.Mr Swenson has specialized in the domestic and international taxation of multinational corporations for more than 20 years.Mr Swenson has served as chairman of the Section 482 Subcommittee of the ABA Tax Section Committee on Foreign Activities of United States Taxpayers, chairman of the International Tax Committee of the District of Columbia Bar, and chairman of the International Tax and Finance Forum.

Mr Swenson's practice principally involves corporate tax planning and tax controversies relating to domestic and international transactions, with particular focus on: the organization and reorganization of multinational corporate structures, including international joint ventures, mergers, acquisitions, and divestitures; intercompany pricing (section 482) matters; international tax planning involving Subpart F, the Foreign Tax Credit, hybrid entities, derivative financial products, insurance matters, PFICs, and foreign currency issues; competent authority matters; tax controversies with the IRS relating to a wide variety of issues; negotiation of Advance Pricing Agreements (APAs); and the implementation of global tax minimization strategies.

Mr Swenson has participated in more than 100 tax controversies involving multinational corporations, the US Internal Revenue Service, the UK Inland Revenue, the Japanese National Tax Agency, the Canadian Inland Revenue, and other revenue authorities around the world, including: Ampex Corp v US, 620 F2d 853 (Ct Cl 1980); Barclays Bank, PLC v Franchise Tax Board of California (US Sup Ct No 92-1384, 1993) (Amicus Curiae for the Japanese Keidanren); BASF Corporation v IRS (TC Nos 30103-89 and 30104-89); Bausch & Lomb, Inc v IRS, 92 TC 525 (1989), aff'd, 933 F2d 1084 (2d Cir 1991), and TCM 1996-57 (Feb. 1996); Boeing Co v US (US Sup Ct No 01-1209, 2002) (Amici Curiae for Brunswick Corp, Caterpillar Inc, Hewlett-Packard Co, Intel Corp, Reebok International Ltd, et al.); Borden, Inc v IRS (TC No 36526-86); Carborundum Co v IRS, 74 TC 730 (1980), acq 1984-2 CB 1; Cincinnati Milacron Inc v IRS (TC Nos 28274-82, 13152-91); Dunlop Holdings PLC v US (US Cl Ct No 71-84T); Equator Bank Ltd v IRS (TC No 20148-91); Goodyear Tire & Rubber Company v US (US Sup Ct No 88-1474, 1989) (Amicus Curiae for Vulcan Materials Co); Honeywell Inc v IRS, TC Memo 1992-453, 64 TCM 437 (1992), aff'd, Dkt No 93-3416 (8th Cir 1994); Inco Electroenergy Corporation v IRS, 54 TCM 359 (1987) and (TC Nos 29491-84, 934-86); Martin Marietta Corp. v US, 85-1 USTC 9219 (Ct Cl 1985) AH Robins Company, Inc v US (US D Ct, ED, Va, No 85-01307-R); Vulcan Materials Co v IRS, 96 TC 410 (1991), aff'd per curiam (11th Cir, 1992); Yamaha Motor Corporation, USA v IRS (TC Nos 2674-88, 26319-88); Zurich Insurance Co v IRS (TC Nos 2608-93, 2609-93, 1021-95, 27200-96).

Mr Swenson has presented outlines and speeches at conferences sponsored by the University of Chicago, Georgetown University, George Washington University, the World Trade Institute, the Tax Executives Institute, the International Fiscal Association, the ABA, the DC Bar, and other institutes, associations, and universities.In addition, he has published numerous articles and papers on international tax issues.Mr Swenson is a graduate of Georgetown University Law Center where he was associate editor of The Tax Lawyer , and is an adjunct professor having taught international tax courses continuously since 1987.

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Marc Levey of Baker & McKenzie in New York chaired the panel, which also included David Swenson of Baker & McKenzie, Washington D.C. and Sean F. Foley, Director of the IRS's Advance Pricing Agreement Program.

C. David Swenson, Esq.--Partner, Baker & McKenzie (Washington, DC)