Zion Levi
Contact
P (202) 568-6377
F (202) 568-6277
zlevi@DearsonLevi.com
Tax Controversy Attorney
IRS Appeals, Private Letter Rulings & Advance Pricing Agreements
Resolve Complex IRS Matters with Strategic Clarity
Zion Levi represents businesses and individuals in high-stakes tax disputes and planning matters involving the Internal Revenue Service. His practice focuses on IRS Appeals, Private Letter Rulings (PLRs), and Advance Pricing Agreements (APAs) - helping clients resolve disputes, reduce exposure, and obtain certainty in complex tax positions.
Whether facing an IRS audit dispute, seeking a favorable Appeals resolution, or evaluating a critical transaction requiring advance IRS guidance, Mr. Levi provides strategic, results-driven representation grounded in deep technical expertise and real-world experience with IRS processes.
Washington D.C
Why Clients Retain Zion Levi
Clients retain Zion Levi when tax exposure is material and strategic decisions will directly affect the outcome.
He represents businesses and individuals in complex matters where:
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The IRS has proposed significant adjustments or penalties
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Transactions involve uncertain or high-risk tax treatment
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The choice between IRS Appeals, litigation, or advance IRS guidance is critical
Mr. Levi advises on:
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When to resolve disputes through IRS Appeals
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When to seek certainty through a Private Letter Ruling
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When to proactively manage transfer pricing through an Advance Pricing Agreement
Clients rely on his judgment not only to advocate their position - but to determine the most effective strategy before positions are finalized and exposure increases.
Strategic Tax Experience
Zion Levi advises businesses, multinational enterprises, investors, and high-net-worth individuals in matters where tax strategy, controversy management, transaction structuring, and tax certainty materially affect outcome.
His practice spans both domestic and international federal tax matters, including:
• IRS Appeals proceedings
• Competent authority considerations
• Federal income tax opinion letters
• Tax-sensitive mergers and acquisitions
• Tax-free reorganizations
• Cross-border investment structures
• IRC §1031 exchanges
• International tax planning and controversy matters
• Strategic tax certainty planning
Many engagements involve situations where legal, financial, operational, and tax considerations must be evaluated simultaneously to achieve the client's objectives while managing long-term exposure.
Why Clients Trust Mr. Levi's Practice
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30+ Years of Focused Experience in IRS Appeals, PLRs, and APAs
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Proven Results in complex, high-dollar tax controversies across industries
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Deep Technical Expertise - Advanced knowledge of tax law, administrative procedure, and transfer pricing
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Credibility with the IRS known for well-supported, practical positions that facilitate resolution
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Strategic, Client-Focused Approach aligned with business and financial objectives.
Representative Tax Matters
Representative matters have included:
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Obtaining favorable Private Letter Rulings involving entity qualification, IRC §42 matters, IRC §1362 issues, IRC §2511 problems, and complex federal income tax questions
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Securing a favorable Private Letter Ruling permitting retroactive restoration of S corporation status
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Achieving substantial reductions in proposed IRS adjustments through strategic Appeals advocacy
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Obtaining full abatement of penalties involving foreign trust reporting and foreign gift issues
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Negotiating bilateral and unilateral Advance Pricing Agreements involving recurring cross-border transactions
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Negotiating multiple unilateral APAs involving foreign exchange transactions and recurring transfer pricing exposure
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Advising multinational businesses regarding transfer pricing disputes, double-taxation concerns, and strategic controversy-management alternatives
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Preparing federal income tax opinion letters involving complex and uncertain tax treatment
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Advising on tax-sensitive acquisitions, restructurings, rollover-equity transactions, and cross-border transactions
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Advising on IRC §1031 exchanges and other tax-sensitive real estate transactions
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Successfully resolving sensitive, high-exposure IRS controversies without litigation through strategic Appeals advocacy
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Advising on reasonable cause determinations, pre-transaction rulings, and risk mitigation strategies for complex transactions
(Representative matters are illustrative and do not guarantee similar results.)
Transfer Pricing, APMA & APA Experience
Zion Levi has experience involving bilateral and unilateral Advance Pricing Agreement matters, transfer pricing disputes, recurring cross-border tax exposure, and strategic tax certainty planning.
His experience includes matters involving:
• Advance Pricing Agreements
• Transfer Pricing Disputes
• IRS Appeals involving transfer pricing issues
• Cross-Border Tax Controversies
• Double-Taxation Considerations
• Strategic Evaluation of APA versus Controversy Alternatives
• Long-Term Tax Certainty Planning
He has also spoken and published on transfer pricing and international tax matters affecting multinational businesses.
Taxpayers evaluating recurring transfer pricing exposure often begin by considering whether an APA is worth pursuing, the expected APA process, expected APA timeline, and the long-term cost of an APA.
Federal Income Tax Opinion Letters
Zion Levi regularly advises clients regarding complex federal income tax issues through formal tax opinions, transaction analysis, and tax-certainty planning.
Opinion-letter engagements often involve significant transactions, uncertain tax treatment, tax-free reorganizations, cross-border structures, and strategic decision-making where advance analysis materially affects risk management and execution.
Core Services
IRS Appeals Representation
An unfavorable IRS determination is not the end of the process. IRS Appeals is a strategic negotiation forum, not a formality.
Zion Levi develops persuasive legal and factual arguments aligned with how Appeals Officers evaluate hazards of litigation, maximizing the potential for favorable resolution while avoiding unnecessary litigation.
He represents clients in:
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Audit disputes and reconsiderations
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Penalty appeals
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Collection Appeals Program (CAP) matters
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Offers in Compromise disputes
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Notice of Deficiency responses
Learn more about:
Private Letter Rulings (PLRs)
Uncertainty in tax treatment can create significant risk.
Zion Levi advises clients on whether a Private Letter Ruling request is appropriate and manages the process from evaluation through submission and IRS engagement - securing clear, authoritative guidance on complex transactions.
Clients often evaluate:
• Private Letter Ruling Process
• Private Letter Ruling Timeline
before deciding whether IRS certainty is strategically justified.
Advance Pricing Agreements (APAs)
For companies with cross-border operations, transfer pricing disputes can be costly and disruptive.
Zion Levi structures and negotiates unilateral, bilateral, and multilateral Advance Pricing Agreements to provide long-term certainty and reduce exposure to IRS penalties and double taxation.
Businesses evaluating transfer pricing certainty frequently consider:
• APA Cost
• IRS Appeals for Transfer Pricing Disputes
before determining the most effective path forward.
Who Zion Levi Represent
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Multinational corporations managing transfer pricing and cross-border tax exposure
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Businesses and partnerships facing IRS audits and disputes
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High-net-worth individuals with complex tax issues
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Companies seeking certainty before executing significant transactions
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Investors and businesses involved in tax-sensitive acquisitions, restructurings, and real estate transactions
A Practical, Results-Driven Approach
Tax controversy is not just about technical rules - it is about how the IRS evaluates risk and makes decisions.
Zion Levi combines technical precision with strategic judgment to:
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Anticipate and mitigate risk early
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Present clear, well-supported positions to the IRS
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Streamline the resolution process
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Protect financial and reputational interests
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Align tax strategy with broader business objectives
Publications & Speaking
Zion Levi has spoken and published on transfer pricing, international tax, IRS controversy matters, tax certainty strategies, formless conversions, and related federal income tax issues affecting businesses and multinational enterprises.
Schedule a Consultation
If you are facing an IRS dispute, evaluating IRS Appeals, considering a Private Letter Ruling, exploring an Advance Pricing Agreement, or addressing a significant tax-sensitive transaction, early strategic assessment can materially affect the outcome.
Contact Zion Levi to discuss your situation and next steps.
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