Patricia Lacey

With more than three decades of tax experience, Patricia provides legal analysis on the application, development, and litigation of IRS policies and regulations, with a particular focus on transfer pricing. She has represented domestic and foreign clients in tax controversies before the IRS audit and appeals functions, and in court, legislative, and policy settings, formulating legal strategies and settlement options related to transfer pricing, tax accounting, and research and development tax issues.

Prior to joining Hunton, Patricia spent 16 years in various roles with the Internal Revenue Service, centered on transfer pricing. As a team leader and then branch chief, she served in the IRS Advance Pricing Agreement Program, overseeing the resolution of complex transfer pricing matters for large multinational corporations. As special counsel (international) in the IRS Office of Chief Counsel, Patricia guided and coordinated multidisciplinary teams of attorneys, economists, and international examiners to analyze the legal, factual, and economic issues in complex transfer pricing audits. She also served as a trial team member on several high-profile transfer pricing cases litigated in the US Tax Court. Finally, Patricia served as deputy division counsel under the Large Business and International Division for several years, where she developed and implemented programs to support IRS goals in international tax compliance.

Before joining the IRS, Patricia served as in-house tax counsel at an American multinational conglomerate for more than a decade, where she was responsible for federal income tax matters under IRS Appeals and in litigation, with a special emphasis on transfer pricing, FSC/DISC issues, research and development tax issues, and tax procedure.

• Volunteer, AARP Foundation Tax-Aide