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Peyton H. Robinson

Peyton H. Robinson

Phone: (801) 746-6300

Fax: (801) 746-6301

Cell: (801) 739-5153

Email:  probinson@lewishansen.com

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Service Profile

Peyton is a partner at the law firm of Lewis Hansen, where he advises clients on US taxation, business law, and aviation related issues.  Peyton is a frequent speaker at tax seminars, and he has written many articles concerning tax controversy and intercompany transactions (“transfer pricing”).

He is also a pilot and legal services attorney for the Aircraft Owners and Pilots Association, and assists clients with FAA enforcement actions and other aviation related issues.

He assists clients with the resolution of domestic tax audits, IRS alternative dispute resolution processes, intercompany transaction policies and practices, business contracts and documentation, legal risk analyses, and general business tax advice and services.

Service Areas:  Business, Taxation, Transfer Pricing, Aviation

Licenses -Admissions -Education

Peyton is an attorney licensed in Utah, Virginia, and the District of Columbia. He is a federal tax practitioner, and he is admitted to the US Tax Court, the Court of Federal Claims, and the DC Circuit Court.

He earned a Bachelor of Science and Juris Doctor from the University of Kansas, and a LLM in Taxation from Georgetown University in Washington, DC.

Peyton is a member of the American Bar Association (and Tax Section), the Aircraft Owners and Pilots Association, the Utah General Aviation Association, and the Lawyer Pilots Bar Association.

Representative Publications

•    Improving the Mutual Agreement Procedure, 23 Global Tax Weekly (CCH) at 5 (Apr. 18, 2013) (co-author) [Link to full publication]
•    An Overview of FAA Enforcement Actions, 25 Utah B.J. 6 (2012)
•    Global Transfer Pricing Controversy, 14 Global Tax Briefing (CCH) 1 (Jan. 27, 2012) (editor and co-author)
•    Global Transfer Pricing Controversy, 12 Global Tax Briefing (CCH) 4 (Apr. 29, 2011) (editor and co-author)
•    At Arm’s Length: IRS Requires Careful Cross-Border Transactions, 10 Utah Bus. Mag. 2 (2010) (co-author)
•    Alternative Dispute Resolution Procedures with IRS Appeals, 23 Utah B. J. 2 (2010)
•    Readdressing Transfer Pricing in a Down Economy, 47 Daily Tax Rep. (BNA) J-1 (Mar. 12, 2010) (co-author)
•    Global Transfer Pricing Controversy, 12 Global Tax Briefing (CCH) 2 (Feb. 23, 2010) (editor and co-author)
•    U.S. Government Continues to Increase Focus on Transfer Pricing, 13 Practical U.S./Int’l Tax Strategies (Thompson Reuters) 7 (Apr. 15, 2009) (co-author)
•    Global Transfer Pricing Update, 47 Tax Notes Int’l 525 (Aug. 6, 2007) (co-author)
•    Global Transfer Pricing Update, 44 Tax Notes Int’l 939 (Dec. 18, 2006) (co-author)
•    The Globally Integrated Multinational, the Arm's Length Standard, and the Continuum Price Problem, 9 Tax Mgmt. Trans. Pricing Rep. (BNA) S-3 (Nov. 1, 2000)
•    The Potential Civil Liability of Law Enforcement Officers and Agencies, 67 Kan. B. Ass'n J. 14 (1998) (co-author)
•    Judge Over Jury:  Judicial Discretion in the Federal Death Penalty Under the Drug Kingpin Act, 45 U. Kan. L. Rev. 1491 (1997)

Representative Presentations

•   2012 Non-Profit Update - Governance and Legal Issues, Utah Association of Certified Public Accountants, Salt Lake City, UT (Sept. 25, 2012)
•   Overview of FAA Enforcement Actions, Cornerstone Aviation, Salt Lake City, UT (July 26, 2012)
•   Overview of FAA Enforcement Actions, Upper Limit Aviation, Salt Lake City, UT (July 10, 2012)
•   Analyzing the Intercompany Transfers of Intangible Property, Council for International Tax Education, Salt Lake City, UT (May 7, 2012)
•   Analyzing the Intercompany Transfers of Intangible Property, Council for International Tax Education, San Diego, CA (Jan. 30, 2012)
•    Managing Transfer Pricing Controversy, Ernst & Young, San Jose, CA (Nov. 10, 2011)
•    Complying with IRS Rules for Intercompany Transactions, Council for International Tax Education, San Francisco, CA (Aug. 16, 2011)
•    Resolution of Tax Controversy, Transfer Pricing 301, Ernst & Young, San Jose, CA (June 23, 2011)
•    Resolution of Tax Controversy, Transfer Pricing 301, Ernst & Young, Irvine, CA (Apr. 20, 2011)
•    Intercompany Transfers of Tangible Property and Financial Arrangements, Council for International Tax Education, San Diego, CA (Jan. 24, 2011)
•    US Transfer Pricing Issues, Ernst & Young, Winnipeg, Canada (Oct. 13, 2010)
•    Resolving IRS Transfer Pricing Controversies, Council for International Tax Education, San Francisco, CA (Mar. 9, 2010)
•    International Tax and Transfer Pricing Hot Topics, Tax Executives Institute, Salt Lake City, UT (Nov. 20, 2008)
•    Developments in Cost Sharing and Intangible Property Planning, Ernst & Young, Seattle, WA and Portland, OR (May 12-13, 2008)
•    Resolving IRS Transfer Pricing Controversies, Council for International Tax Education, Santa Monica, CA (Nov. 13, 2007)
•    Basics of Transfer Pricing, Tax Executives Institute, Santa Clara, CA (June 13, 2007)
•    Transfer Pricing: Advance Pricing Agreements Versus the Alternatives, Ernst & Young Tax Executives Workshop, Carmel, CA (June 28, 2006)
•    Recent Transfer Pricing Developments, Ernst & Young, Portland, OR (Nov. 17, 2005)
•    Proposed Cost Sharing Regulations, Ernst & Young, San Jose, CA (Oct. 25, 2005)
•    Discussion: Government APA Practice Versus Private APA Practice, Internal Revenue Service, Washington, DC (Oct. 6, 2005)
•    IRS Dispute Resolution: Advance Pricing and Pre-Filing Agreements, Tax Executives Institute, Santa Clara, CA (Sept. 20, 2005)
•    Administrative Resolution of Transfer Pricing Disputes, Council for International Tax Education, Santa Monica, CA (June 21, 2005)
•    The Tax Authorities’ New Interest in Permanent Establishments, International Association of Drilling Contractors, Santa Fe, NM (June 3, 2005)
•    Transfer Pricing Controversy Management, Tax Executives Institute, Irvine, CA (Feb. 2, 2005)
•    International Tax Technical Training – Advance Pricing Agreements, Internal Revenue Service, Washington, DC (Sept. 15, 2003)

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