Patricia A. Brown
Director, Graduate Program in Taxation
J.D., University of California Berkeley
B.S.F.S., Georgetown University School of Foreign Service
Telephone: 305-284-5946 | Office: B351
Patricia A. Brown is an internationally-recognized expert in the field of international taxation, with specialties in tax treaty policy and interpretation and the international taxation of financial products and institutions.
She began her career in 1987 at the Wall Street office of the law firm of Cleary, Gottlieb, Steen and Hamilton where she specialized in the tax treatment of cross-border financial transactions and financial institutions. Within a year, she was posted to the London office of the firm, where she was the firm's only U.S. tax lawyer based outside the United States. While in London, she handled a wide variety of tax issues relating to both common and more exotic financial instruments and financing transactions.
After returning to the United States, her practice expanded to encompass the taxation of financial institutions themselves.
In 1994, Professor Brown joined the U.S. Treasury Department as an Attorney Advisor in the Office of International Tax Counsel. Her initial assignments built on her experience in the New York and London financial markets.
Outside the financial community, Professor Brown is best known for overseeing and coordinating the U.S. tax treaty program as the Treasury Department's Deputy International Tax Counsel (Treaty Affairs). In addition to ensuring consistency in terms of negotiations and interpretation, she was personally involved in the negotiation of all U.S. tax treaties and protocols that entered into force between 1999 and 2008.
As a result, she has worked closely with government officials from every inhabited continent, from large and small countries, and from developed and developing countries. For much of 2005, she was Acting International Tax Counsel, during which time she was directly responsible for all international tax matters within the Office of Tax Policy.
Since 2007, she has served as a full-time consultant to the Organisation for Economic Co-operation and Development, developing guidelines and procedures for the cross-border taxation of portfolio investors. Professor Brown has also lectured and spoken extensively on a variety of topics relating to tax treaties and cross-border financial transactions.
Professor Brown received her B.S.F.S., magna cum laude, Phi Beta Kappa, from Georgetown University's School of Foreign Service and her J.D. from the University of California (Berkeley), where she was made a member of Order of the Coif.
Professor Patricia Brown says "The offshore voluntary disclosure programs are, as I understand it, about avoiding criminal tax liability," in the article "Is Offshore Tax Evasion Costing Me, You & Uncle Sam Billions?" at Card Hub.