Reeves C. Westbrook

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Covington & Burling LLP
1201 Pennsylvania Avenue, NW
Washington, DC 20004-2401
Tel: 202.662.5150




  • Yale Law School, J.D., 1974
    • Yale Law Journal, Editor
  • Vanderbilt University, B.A., 1971
    • magna cum laude
    • Phi Beta Kappa

Bar Admissions

  • District of Columbia
  • U.S. Tax Court
  • U.S. Court of Federal Claims

Reeves Westbrook is the co-chair of the firm's tax practice group.  His practice concentrates on the needs of large corporate taxpayers, including both counseling and tax controversies.

Mr. Westbrook has provided counseling on international asset transfers and tax optimal corporate structures, acquisitions and dispositions, cross-border transfer pricing, cross-border financings, tax credit planning, foreign and domestic joint ventures and partnerships.  Mr. Westbrook also counsels clients on regulatory and legislative issues and matters before the national office of the Internal Revenue Service.

Mr. Westbrook's controversy experience includes audits, administrative appeals and litigation.  Mr. Westbrook has handled controversies in a broad spectrum of subject matter areas, including foreign tax credits, accounting and capitalization, valuations and purchase price allocations, research and development credits and deductions, income and expense reallocations under Section 482, foreign tax credits, accounting and capitalization, valuations and purchase price allocations, research and development credits and deductions, treatment of corporate reorganizations and restructurings, computation of allowable FSC benefits, treatment of items under the consolidated return regulations, allocations under Section 861, partnership issues, allowance of losses on subsidiary stock, form over substance and Subpart F inclusions.

Representative Clients: Eastman Kodak Company, GE Capital Corporation, International Business Machines Corporation, ITT, Norfolk Southern Corporation, United Technologies Corporation, and Vivendi.

Mr. Westbrook is Co-Chair of the International Bar Association’s Taxes Committee and has chaired its Transfer Pricing and Litigation Subcommitttee.  He also served as Program Vice-chair for the 2010 IBA annual meeting in Vancouver, and recently co-chaired a panel titled, "The New Focus on Tax and Development: What Does it Mean for Multinational Business?" at the Europe/USA Tax Strategies Conference sponsored by the ABA, IBA, and IFA.

Honors and Rankings

  • The Best Lawyers in America, Tax (2009-2014)
  • Chambers USA - America's Leading Business Lawyers, Tax (2008-2013)
  • Legal 500 US, Tax (2012-2013) 
  • Washington DC Super Lawyers, Tax (2013)
  • The International Who's Who of Corporate Tax Lawyers (2010-2013)
  • Martindale AV Preeminent

Publications and Speeches

  • "Opinion Practices in Light of Aggressive Government Positions," 14th Annual Tax Planning Strategies – U.S. and Europe (4/10/2014)
  • "CBP Finalizes Ruling Allowing Post-Importation Pricing Adjustments," Covington E-Alert (6/5/2012), Co-Author
  • "Examination and Appeals," Practical Guide to U.S. Transfer Pricing, Third Edition (December 2011), Co-Author
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