Patricia A. Brown is IBFD’s Professor-in-Residence for 2020. She is also the Director of the Graduate Programs in Taxation and Taxation of Cross-Border Investment at the University of Miami School of Law. Her primary fields of expertise are in the interpretation of tax treaties, the international taxation of financial institutions and financial products and cross-border taxation of pensions and pension funds.
She began her career in 1987 at Cleary, Gottlieb, Steen and Hamilton, where she worked in the New York and London offices. In 1994, she joined the Office of the International Tax Counsel at the U.S. Treasury Department, serving as the Deputy International Tax Counsel (Treaty Affairs) from 1997 to 2006 and Acting International Tax Counsel for most of 2005. As Deputy International Tax Counsel, she was responsible for overseeing and coordinating the U.S. tax treaty program as well as serving as Head of Delegation for the negotiation of a large number of U.S. treaties and protocols.
While at Treasury, she was a U.S. delegate to the Committee on Fiscal Affairs, Working Party 1, Working Party 6, the Transfer Pricing Steering Group, the Special Sessions on Innovative Financial Transactions and other working groups and working parties. She was the Chair of the Sub-group of Working Party 1 that drafted the 2005 changes to the Commentary on Article 18 (Pensions). She was also made a member of the UN Group of Experts on International Tax Cooperation by the Secretary General of the United Nations and was elected First Vice-Chair in 2003. After leaving the Treasury Department, Ms. Brown served as a Senior Adviser, Financial Transactions at the OECD where she served as the primary Secretariat member for the CIV and TRACE projects.
Ms. Brown has been a visiting professor at the University of Leiden and IE Law School in Madrid. She also has an active consulting practice, having served as the government’s expert witness in connection with the government’s successful denial of foreign tax credits to the taxpayer in Lehman Brothers Holdings, Inc. v. United States of America, 531 B.R. 339 (2015).
She was the General Reporter for the 2012 IFA Congress on the Debt-Equity Conundrum and is the chapter author on Pensions for the IBFD Global Tax Treaty Commentaries. She has also authored numerous articles on the history and interpretation of tax treaties. She is a frequent speaker on tax treaty issues, including at IFA Annual Congresses in New Delhi (1997), Vienna (2004), Kyoto (2007), Brussels (2008), Boston (2012), Madrid (2016) and Seoul (2018).
Ms. Brown received her B.S.F.S., magna cum laude, Phi Beta Kappa, from the Georgetown University School of Foreign Service and her J.D. from the University of California (Berkeley), Boalt Hall School of Law, where she was elected to Order of the Coif.