Covington & Burling LLP

Samuel M Maruca

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Practice Areas

Federal income tax, focusing on large-case international tax controversies, especially disputes involving transfer pricing issues. Represents US and foreign-based multinational companies in the pharmaceutical, communications, heavy manufacturing, consulting, entertainment, and retail sectors, in matters at the audit level, in IRS Appeals, in mediation, in competent authority, and in the courts. From 2011-2014, served as the first Director of Transfer Pricing Operations at the IRS, with national responsibility for transfer pricing enforcement and resolution of double tax disputes.

Professional Memberships

ABA Tax Section; International Fiscal Association.


Georgetown University (JD, with honors, 1982); Yale University (BA, with honors, 1977).