Wealth & Risk Management Blog

William Byrnes (Texas A&M) tax & compliance articles

Transfer Pricing

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Lexis’ Practical Guide to U.S. Transfer Pricing is updated annually to help multinationals cope with the U.S. transfer pricing rules and procedures, taking into account the international norms established by the Organisation for Economic Co-operation and Development (OECD). It is also designed for use by tax administrators, both those belonging to the U.S. Internal Revenue Service and those belonging to the tax administrations of other countries, and tax professionals in and out of government, corporate executives, and their non-tax advisors, both American and foreign.  Fifty co-authors contribute subject matter expertise on technical issues faced by tax and risk management counsel.  Free download of chapter 2 here

Contents

CH 1: Overview of Transfer Pricing
CH 2: Framework for U.S. Transfer Pricing Analysis Under Treasury Regulation Section 1.482-1 — OECD Guidelines Compared
CH 3: Determination of Related Person Status
CH 4: Finding and Selecting Comparables
CH 5: Comparable Uncontrolled Price (CUP) Method
CH 6: Resale Price Method (RPM) and Alternatives to Traditional Buy-Sell Distributors
CH 7: Cost Plus Method
CH 8: Transfer Pricing Rules and Methods for Intangible Property
CH 9: Comparable Profits Method
CH 10: Profit Split Methods
CH 11: Unspecified Methods
CH 12: Functional Analysis and Choosing the Best Method
CH 13: Cost Sharing Arrangements
CH 14: Transfer Pricing for Services Under the 1968 and 2009 Treasury Regulations
CH 15: Determining Arm’s Length Interest and Rent
CH 16: Financial Industry Transfer Pricing Issues
CH 17: Second-Level Effects of Transfer Pricing Adjustments
CH 18: Documented Self-Compliance and Transfer Pricing Penalties
CH 19: Advance Pricing Agreements (APAs)
CH 20: IRC Sections 6038A and 6038C: Record-Keeping, Record Production, and Reporting for Foreign-Owned Groups
CH 21: Examination and Appeals
CH 22: Competent Authority to Avoid Double or Excessive Taxation From Transfer Pricing Adjustments
CH 23: Transfer Pricing Litigation
CH 24: Relationship of Section 482 to Other Code Sections
CH 25: Transfer Pricing Effects of Customs Actions and Customs Effects of Transfer Pricing Actions
CH 26: State Tax Transfer Pricing Issues
CH 27: International Strategy for Transfer Pricing Compliance: A Checklist for Multinationals
CH 28: Transfer Pricing Aspects of Business Restructurings — Chapter IX of the OECD Guidelines
CH 29: Application of the Comparable Profit Split Method (CPSM) to Business Service Providers

Lexis Transfer Pricing Authors & Industry’s Top Experts

William H. Byrnes (principal author) is an author of eight LexisNexis international tax compendium, three Tax Facts books of National Underwriter, hundreds of tax articles, among other books and government reports. In 1994, he developed an international tax graduate program, pioneering in 1998 the first online LL.M. offered by an ABA law school (International Taxation). Academically, he has obtained the titles of Professor of Law with Tenure (St. Thomas) and of Associate Dean (Thomas Jefferson). Professionally, he served as a Senior Manager then an Associate Director of international tax at Coopers & Lybrand (South Africa), specializing in transfer pricing and functional analysis. Professor Byrnes undertook a three-year transfer pricing fellowship at the IBFD in conjunction with an LL.M. at the University of Amsterdam.

Robert T. Cole (in memoriam) in 1973, founded the law firm which became Cole Corette & Abrutyn where he practiced through 1996. In 1997 he founded Alston & Bird’s International Tax Group and practiced in that firm from 1997 through July 2012. In August 2012 he joined the Internal Revenue Service’s Office of Transfer Pricing Operations, commencing his third period of government service. Mr. Cole served in the U.S. Treasury from 1967 to 1973 and was appointed as the first International Tax Counsel in 1971. He served in the JAG Corps of the United States Air Force from 1957 to 1959. Mr. Cole received his LL.B in 1956 from Harvard Law School and his B.S. in 1953 from the Wharton School of Finance, University of Pennsylvania, and an academic postgraduate diploma in law in 1959 from the London School of Economics. He is a member of the Council of the USA branch of the International Fiscal Association; a past vice-chair of the Tax Committee of the National Foreign Trade Council and a member of the Tax Section of the American Bar Association.

Valerie Amerkhail is a Director, Transfer Pricing with Economic Consulting Services, LLC. She has specialized in transfer pricing economics since 1986, first with Deloitte & Touche, then with Coopers & Lybrand, before joining ECS in 1998. Her work with international tax attorneys and clients has involved transfer pricing dispute resolution at all stages of IRS field examinations, appeals, Advanced Pricing Agreements and Competent Authority negotiations, as well as examinations by Japanese, Korean, European, and other non-U.S. tax authorities. Ms Amerkhail served as a Principal Analyst at the Congressional Budget Office, where she was responsible for CBO’s corporate tax projections.

Henry J. Birnkrant is a partner at Alston & Bird and chairs its Tax Section. His practice is focused on transfer pricing matters and U.S. taxation of various types of domestic and cross-border transactions. Mr. Birnkrant has secured many advance pricing agreements (APAs) and resolved numerous transfer pricing disputes with the IRS at the examination and appeals levels. His practice has also included securing competent authority relief from transfer pricing adjustments initiated by both the IRS and foreign tax authorities. Mr. Birnkrant is a graduate of the University of Rochester, from which he received his B.A. in Economics. He received his J.D. from Columbia University School of Law and an LL.M. in taxation from New York University School of Law.

William E. Bonano is a partner at the San Francisco Office of Pillsbury Winthrop Shaw Pittman LLP. His practice includes international tax planning and IRS controversy matters, including representing clients before IRS Examinations, Appeals and in litigation. Mr. Bonano assists in negotiating Advance Pricing Agreements and in representing clients in Competent Authority proceedings. Mr. Bonano was formerly an International Special Trial Attorney with the Internal Revenue Service. He has litigated over 25 tax cases through opinion, including a number of transfer pricing cases. He received a J.D. from the University of Washington School of Law, is a frequent lecturer on transfer pricing issues and has written a number of articles on that subject.

Patrick J. Browne Jr. is of counsel at the law firm of Jones Day. His practice focuses on general corporate tax issues and international tax planning, including structuring and drafting stock purchase and asset acquisition agreements, Section 355 distributions, tax-free reorganizations, cross-border tax planning, FIRPTA-related issues, tax treaty issues, and FBAR filing requirements (Form TD F 90-22.1). Before joining Jones Day, Mr. Browne was a senior manager in the national tax office of a Big Four accounting firm. Prior to that, he was an associate at a New York-based international law firm where he focused on advance pricing agreements for a Fortune 100 company and various U.S. international tax issues, such as foreign tax credit optimization and subpart F planning.

William W. Chip is Senior Counsel in the international law firm Covington & Burling, resident in their Washington, D.C. office. Mr. Chip has over 30 years of experience advising and representing multinational clients with respect to cross-border transfer pricing and other international tax matters, including the resolution of transfer pricing controversies at the examination and appeals level and through Competent Authority proceedings and the IRS Advance Pricing Agreement Program. Over the course of his career, Mr. Chip he has chaired the Transfer Pricing Subcommittees of the ABA Tax Section and the U.S. Council on International Business and has served as the Transfer Pricing Technical Director of a Big Four accounting firm. He is a long-standing member of the Tax Committee of the OECD’s Business & Industry Advisory Committee (BIAC), and in that role has been an active participant in the OECD’s project on Base Erosion & Profit Shifting (BEPS). Having served as transfer pricing advisor to the owners, CFOs, and senior tax executives of both established and emerging global enterprises in the financial, commodities, life sciences, and energy industries, he is nationally recognized for his specialized expertise in those industries. Mr. Chip received his B.A. in Economics from Yale University in 1971, his M.A. in Economics from Cambridge University in 1973, and his J.D. from Yale University in 1979.

Justin M. Dahnert is a Transfer Pricing professional in the Chicago office of PricewaterhouseCoopers LLP (“PwC”). Mr. Dahnert is a graduate of the University of Wisconsin where he received his B.B.A. and Master of Accountancy degrees. His work at PwC has included transfer pricing, personal financial services, and private company services. Prior to transfer pricing, he assisted clients with assurance, and U.S. and international tax compliance and planning services. Mr. Dahnert’s transfer pricing background has involved documentation reports and planning engagements spanning various jurisdictions and in accordance with both U.S. transfer pricing law and the Organisation for Economic Co-operation and Development’s (“OECD”) guidelines.

Ryan M. Decker is a Transfer Pricing professional with PwC. Dr. Decker is based in Chicago and is a graduate of the University of Illinois at Chicago, where he received his Ph.D. and M.A. in Economics; and North Central College, where he received a B.S. in Economics and Finance. Dr. Decker’s work with PwC focuses primarily on assisting clients in analyzing the arm’s length nature of their intercompany transactions for both compliance and planning purposes. Dr. Decker is experienced in performing macro- and microeconomic research related to a variety of transfer pricing issues, such as: transfer pricing adjustments in recessionary environments, the economic useful life of advertising, and incentives within licensing arrangements. Notably, Dr. Decker has extensive experience in assisting clients with preparation of transfer pricing documentation as required by U.S. transfer pricing law and the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

Dr. Lorraine Eden is Professor of Management and Mays Research Fellow in the Mays Business School at Texas A&M University. At Texas A&M, Prof. Eden teaches courses on multinational enterprises (MNEs), transfer pricing (the pricing of transactions within MNEs), and the economics of international business. Over 100 of her former students are networked through the LinkedIn group Transfer Pricing Aggies. She has 150+ scholarly publications, including articles in Academy of Management Journal, Academy of Management Review, Canadian Journal of Economics, Journal of International Business Studies, and Organization Science. Her best-known book is Taxing Multinationals: Transfer Pricing and Corporate Income Taxation in North America (University of Toronto Press, 1998). She has been a Fulbright Scholar, a Pew Fellow, and a receiver of multiple teaching, research and professional awards including election as a Fellow of the Academy of International Business (AIB) in 2004 and receipt of the AIB President’s Award in 2012. She is the founder of WAIB (Women in the Academy of International Business), an organization with 1600 members worldwide, and former Editor-in-Chief of the Journal of International Business Studies, the top scholarly journal in the field of international business.

Rocco V. Femia is a member of Miller & Chevalier, Chartered. His practice focuses on international tax planning for domestic and foreign-based enterprises, and on assisting such enterprises in avoiding or resolving controversies with the Internal Revenue Service and foreign tax authorities involving U.S. international tax rules, transfer pricing, and U.S. tax treaties. Mr. Femia is a former Associate International Tax Counsel at the U.S. Department of the Treasury, Office of Tax Policy. Mr. Femia is a former Adjunct Professor at the Georgetown University Law Center. Mr. Femia graduated from Georgetown University Law Center in 1995. He received his B.A. in Economics from Duke University in 1991.

Paul Flignor, a Principal with DLA Piper US (LLC), is an expert in intercompany pricing and intellectual property valuation, and has over 15 years of professional experience in resolving pricing and valuation issues in the areas of international tax planning, controversy resolution, transaction support, licensing, and financial economics. He is noted particularly for integrating business strategy and financial economics to solve complex valuation problems of leading companies. Before coming to DLA Piper, Mr. Flignor was a partner with PricewaterhouseCooper’s transfer pricing and valuation practice and he also was a principal in the strategy and economic consulting practice at A.T. Kearney, a leading international management consulting firm. He is an adjunct professor at Northwestern University where he teaches courses in business and law.

Sean Foley is a Principal with KPMG LLP and the Global Leader of KPMG’s Global Transfer Pricing Services. Mr. Foley has over 20 years assisting multinational enterprises with international tax and transfer pricing issues. Before joining KPMG, Mr. Foley was the Director of the IRS Advance Pricing Agreement Program, and a special counsel to the IRS Chief Counsel (International). He clerked for Justice Ruth Bader Ginsburg when she sat on the D.C. Circuit and served as Legislative Director to Congressman Sander Levin, currently the ranking member of House Ways and Means Committee. Mr. Foley has been an adjunct professor in the LL.M. programs at the Georgetown University Law Center and the University of Florida. He is a past chair of the American Bar Association Transfer Pricing Committee. Mr. Foley has a B.S. in Chemistry and Economics from the University of Michigan, and a J.D. summa cum laude and a LL.M. with honors from the Georgetown University Law Center.

Christopher S. Hanfling is an associate in the tax group at the law firm of Jones Day. Before joining Jones Day, Mr. Hanfling was an editor of Tax Law Review at NYU, and received the Bruce I. Hochman Award for Excellence in the Study of Tax Law from UCLA School of Law.

Steven P. Hannes is a partner in the law firm of McDermott Will & Emery LLP based in the Washington, D.C. office. As a member of the McDermott Tax Department, he focuses on advising U.S. and foreign based multinational corporations on structuring their cross-border transactions, as well as representing multinationals in tax controversies. Mr. Hannes founded and chairs the Transfer Pricing Discussion Group, which consists of U.S. and foreign-based multinationals who meet regularly to discuss transfer pricing and related matters. He founded the Transfer Pricing Discussion Group for multinationals. Prior to entering private practice in 1982, Mr. Hannes was the associate international tax counsel in the Office of the Assistant Secretary (tax policy) of the U.S. Department of the Treasury. Before joining the Treasury, he was chief of the international rulings group in what was then called the Office of the Assistant Commissioner (technical) of the IRS. He is a former president of the USA Branch of the International Fiscal Association and a member of its Executive Committee. He received his J.D. in 1970 from New York University’s School on Law and his B.A. in 1967 from Amherst College.

Stuart L. Harshbarger, Ph.D. is a Vice President in NERA’s transfer pricing and intellectual property practices. He has been qualified as an expert in economics before Federal and State courts, testifying on antitrust, breach of contract, and product liability matters. He has extensive tax audit and controversy experience in transfer pricing and business valuation in the United States and elsewhere. Prior to joining NERA, Dr Harshbarger worked for PwC, DRI/McGraw-Hill, Argonne National Laboratory, the Washington Gas Light Company, and the US Department of Energy. Dr Harshbarger established the Marsh & McLennan and NERA Economic Consulting Lecture Series on Current Economic Events at The George Washington University where he also established and chaired the Economics Alumni Advisory Committee. He is the past Vice President and Program Director of the National Economist Club in Washington DC. His publications include the chapter, Application of Profit Split Method to Business Service Providers, in Lexis’ Practical Guide to U.S. Transfer Pricing, and articles in BNA Tax Management Transfer Pricing Report, International Tax Review, Journal of Computers and Operations Research, Energy Economics, and Public Utilities Fortnightly. He received his PhD in economics from The George Washington University, and his BA in economics, with honors in economics, from Indiana University, Bloomington.

Karina Siegel Haum is of counsel to Al-Sarraf & Al Ruwayeh in Kuwait. She received a Bachelors Degree from the University of California, Irvine, in 1982, a Juris Doctorate from the University of California, Los Angeles, in 1985, and an LLM in Taxation from New York University, in 1987. Before joining Al Sarraf & Al Ruwayeh in January 2008, Karina was a partner with an international law firm in New York City. Her areas of expertise include international taxation, mergers and acquisitions, private equity and cross border transactions. She is widely published, in both English and German, in the areas of international taxation and private wealth planning. Karina is fluent in German, English and French.

Dr. Harlow N. Higinbotham is senior vice president of the international consulting firm NERA Economic Consulting where he applies his expertise to the intercompany pricing controversies encountered by NERA’s clients around the world. He is a Ph.D. economist and Chartered Financial Analyst (CFA) with more than 25 years of consulting and research experience in the public, private, and academic sectors. Dr. Higinbotham received a Ph.D. in economics from the University of Chicago and an A.B. in applied mathematics from Harvard University, in addition to graduate studies at the London School of Economics. He has published extensively on the subject of transfer pricing and is a frequent speaker at industry conferences. He has also served as an expert witness in a variety of government proceedings related to cost determination.

Dr. Thomas Horst is the founder and a Managing Director of Horst Frisch Incorporated, an economic consulting firm in Washington, D.C. He specializes in transfer pricing of U.S. and foreign-based multinationals, analyses of the economic substance of complex agreements and transactions, and U.S. Federal Energy Regulatory Commission regulation of oil pipelines. In addition to advising private- and public-sector clients, Dr. Horst has testified as an expert witness before the U.S. Tax Court in four transfer-pricing cases, a case involving the apportionment of interest expense between foreign and domestic income, and a case addressing the income tax consequences of a complex partnership agreement. He testified in the Superior Court of Justice of Ontario, Canada, about the impact of transfer pricing on a Canadian subsidiary’s minority shareholders. Dr. Horst has also testified several times before the FERC on cost-of-service and other regulatory issues involving oil pipelines. Prior to establishing Horst Frisch in 1988, Dr. Horst conducted a similar consulting business at Deloitte Haskins & Sells (now Deloitte) and at Taxecon Associates, Inc. He was the Director of the International Tax Staff at the U.S. Treasury Department from 1977 until 1981. Before 1977, he served on the faculty of Harvard University and the Fletcher School of International Law and Diplomacy at Tufts University, and was a Research Associate at The Brookings Institution. He has published several books and articles mainly addressing various transfer-pricing and international tax issues. Dr. Horst received his Ph.D. and M.A. in Economics from the University of Rochester and his B.A. from Amherst College.

Leon Andrew Immerman is a partner in Alston & Bird’s Federal Income Tax Group and the International Tax Group. He concentrates on federal income tax matters, including domestic and international tax planning and transactional work for joint ventures, partnerships, limited liability companies, and corporations. Mr. Immerman received his J.D. degree from the Yale Law School in 1982. He received advanced degrees from Princeton University and the University of Minnesota, and an undergraduate degree from Carleton College in 1973.

Dr. Donald J. Jankowski was a transfer pricing partner in the Chicago office of PricewaterhouseCoopers LLP, having retired July 1, 2014. His 20 years of experience covers virtually all facets of transfer pricing, including documentation, structural tax rate reduction, APA and controversy resolution engagements. He received a Ph.D. and M.S. in Economics from Purdue University and an M.A. in Economics and a B.S. in Business Administration from Marquette University.

Michelle Johnson is a Managing Director of Duff & Phelps. She has significant experience advising clients on transfer pricing and valuation matters—including ASC 740 (FIN 48) recognition and measurement analyses, advanced pricing agreements, cost-sharing analyses, buy-in valuations, supply chain restructuring, and tangible and intangible transfer pricing documentation. She has consulted with companies in such wide-ranging industries as financial services, technology, pharmaceuticals, retail, and many others. Previously, Mrs. Johnson led the development of Ceteris’ FIN 48 service line and pioneered several thought leadership publications on behalf of the firm. She is an award-winning speaker and has presented at numerous conferences and seminars regarding transfer pricing issues. She served as co-editor of Wolter Kluwer’s Guide to International Transfer Pricing: Law, Compliance and Tax Planning Strategies, and is co-author of BNA Tax Management Portfolio on ASC 740-10 (FIN 48) and transfer pricing.

Karl L. Kellar is a partner at the law firm of Jones Day. His practice focuses on a wide variety of international and domestic tax issues arising in cross-border transactions, including transfer pricing, tax planning for international transaction flows, structuring international business operations, and resolving tax disputes with the IRS and foreign governments. Mr. Kellar has advised multinational corporate groups concerning the restructuring of their U.S. operations. He has also advised U.S.-based companies in structuring their foreign operations, including issues associated with closing foreign operations to achieve a more tax-efficient structure, and the transfer of intangible assets offshore. Before joining Jones Day, Mr. Kellar was the acting director of the IRS Advance Pricing Agreement (APA) Program. He also represented the United States before the Organization for Economic Cooperation and Development (OECD). Earlier, Karl Kellar was a tax litigator for the United States Department of Justice, and he has extensive experience in tax controversy matters at the administrative level and in federal courts.

Sam Maruca, Esq. is a partner of Covington & Burling, resident in its Washington, D.C. office. From 2011–2014, Mr. Maruca served as the first Director of Transfer Pricing Operations in the Large Business & International Division of the Internal Revenue Service, where he had national responsibility for transfer pricing compliance and double tax cases under US tax treaties. Since 1983 he has practiced broadly and exclusively in the area of federal income tax, focusing in recent years on large-case controversies, including complex transfer pricing disputes. He has represented both US and foreign-based multinational companies in the pharmaceutical, bio-tech, communications, heavy manufacturing, entertainment, and retail sectors, in matters at the audit level, in IRS Appeals, in mediation, in competent authority, and in the courts.

Ethan D. Millar is a partner at the law firm of Alston & Bird LLP. His practice focuses on multistate tax and unclaimed property law, and he represents major business entities across the U.S. in audits, administrative appeals, litigation, and corporate transactions, including mergers, acquisitions, restructurings, liquidations, joint ventures, and public and private securities offerings. Mr. Millar has served as an adjunct professor at Emory University School of Law, where he taught a class on multistate taxation, and has also served on the faculty for state income tax schools conducted by the Council on State Taxation and the Institute of Professionals in Taxation. He also serves as Chair of both the State and Local Tax Subcommittee and the Unclaimed Property Subcommittee for the Business Law Section of the American Bar Association. Mr. Millar received his J.D. from UCLA Law School, Order of the Coif, and also graduated, summa cum laude, from UCLA with a B.S. in Mathematics/Applied Science and Economics.

Jerrie Mirga is a Vice President of Economic Consulting Services, LLC. Since the early 1990s, her work has focused on transfer pricing economics. She advises clients on transfer pricing issues involving intangibles, services, and tangible property and prepares transfer pricing analyses for many purposes, including planning, U.S. and non-U.S. documentation, Advance Pricing Agreements, and dispute resolution during audits and Appeals. Ms. Mirga received her B.A. from the College of William & Mary and her M.B.A. from the George Washington University.

James R. Mogle is a retired partner of the law firm of Mayer, Brown & Platt, where he was a member of the Tax Controversy Group. He is a former international tax counsel for the Treasury Department, where he was responsible for the development of the 1993 Section 482 Regulations, as well as a former chief tax officer with General Motors Corporation. He is also a former partner with PricewaterhouseCoopers. He received a B.S. from Northwestern University, an M.B.A. from Stanford University, a J.D. from American University, and an LL.M. (tax) from George Washington University.

Matthew P. Moseley is a senior associate in Alston & Bird’s Federal & International Tax Group. Mr. Moseley concentrates his practice on the U.S. taxation of various types of domestic and cross-border transactions and on transfer pricing matters. Mr. Moseley is a graduate of the University of Virginia, from which he received his B.S. in Chemical Engineering. He received his J.D. from the University of California, Hastings College of the Law, and an LL.M. in taxation from Georgetown University Law Center.

Michael T. Petrik is chair of Alston & Bird’s State and Local Tax group. Mr. Petrik concentrates his practice on multistate tax planning for businesses, including income tax, franchise tax, sales/use tax, and other state and local taxes. He also maintains an active administrative tax dispute and negotiation practice, including audit appeals, the negotiation of special filing or apportionment methods, and voluntary disclosure “amnesty” applications. Mr. Petrik received his J.D. in 1983 from Duke University School of Law and his B.A. and B.S. degrees in 1979 from Eastern Illinois University.

Whitney Pilch is completing her Juris Doctorate/Master of Business Administration candidacy at Thomas Jefferson School of Law and San Diego State University. Her specialization, under the tutelage of Professor William Byrnes, is international taxation from a Latin American perspective. Whitney is an update contributor for Foreign Tax and Trade Briefs, and Professor Byrnes’ publication editor for Practical Guide to U.S. Transfer Pricing and for Lexis Guide for FATCA Compliance.

Bob A. Rutkowski is a Vice President with Duff & Phelps, LLC’s Transfer Pricing group in Boston. His work with Duff & Phelps has involved advising clients on a variety of transfer pricing, economic, and valuation issues, with a focus on U.S. and foreign transfer pricing documentation, advanced pricing agreements, global transfer pricing planning and implementation analyses, and intellectual property valuation matters. Mr. Rutkowski is a graduate of Colgate University, from which he received his B.A. in Mathematical Economics.

Dr. George L. Salis is a recognized economist and lawyer specializing in the area of international economic law, including trade, global taxation, and transfer pricing. Presently, he serves as Principal Senior—Tax Compliance at Vertex, Inc., one of the top tax software companies in the world. He is an adjunct professor of Texas A&M University School of Law for transfer pricing and international tax risk management courses as well as an adjunct professor of international taxation and of the transfer pricing concentration at Thomas Jefferson School of Law’s Graduate International Taxation Program in San Diego, California. Dr. Salis received his Ph.D. (Union) in International & Comparative Law & Economic Policy, and his LL.M. with Honours (Magna Cum Laude) (Thomas Jefferson) in International Taxation and Financial Services. He read law at the University of Wolverhampton and iIn 1998, he received his LL.B. Honours law degree at the University of Wolverhampton School of Law in England, and later received the Specialist Diploma in European Union Law from Holborn College London & Oxford University. He earned an M. A. in Legal & Ethical Studies from The University of Baltimore, in 1988. He also holds two Bachelor’s degrees, one in in Economics & Political Science (dual concentration) with Honours, and another in Philosophy & Humanities. In 2014, he attended the Academy of European Law at the European University Institute (Florence, Italy) and received its Advanced Certificate in EU Law.

Emily W. Sanborn is a VP with Duff & Phelps, LLC’s Transfer Pricing group in Atlanta. Emily’s work with Duff & Phelps involves assisting clients in determining the arm’s length pricing of controlled transactions and implementing global transfer pricing policies. Emily has prepared U.S., OECD, and local country transfer pricing documentation for tangible, intangible, and service transactions. Emily has also assisted in the design, preparation, and management of worldwide comparable company analyses, transfer pricing litigation support, and management fee analyses. Emily has worked in a broad range of industries including technology, software, industrial, oil and gas, and consumer products. She is a graduate of Emory University, where she received her degree in Economics and Chinese Studies.

Mark W. Schuette is a Managing Director with Duff & Phelps, LLC’s Transfer Pricing group in Atlanta. Mark’s work with Duff & Phelps includes consulting with clients on business accounting, tax, and valuation issues. He has conducted transfer pricing studies for global companies located across a six-state region, and is regularly sought out for his expertise with state and local tax transfer pricing matters. In addition, he has more than five years of experience providing litigation services to attorneys and their clients, including preparing for and participating in trial depositions and delivering expert witness testimony. Mark is a frequent speaker on transfer pricing topics and co-authored the BNA Tax Management Portfolio on Accounting for Uncertain Tax Positions in Transfer Pricing under ASC-740 (FIN 48) published in 2012. Mark received both his undergraduate degree and M.B.A. from Loyola University Maryland, and is a member of the American Institute of Certified Public Accountants.

Ralph H. Sheppard is a partner in Meeks, Sheppard, Leo & Pillsbury, with offices in New York, Connecticut and California. Since 1986, his practice has involved giving advice and assistance on import and export law to both domestic and foreign companies. Since 1986, his practice includes representation of importers and exporters before U.S. Customs and Border Protection, the Department of Commerce and the Court of International Trade and other Federal agencies and courts. He received his undergraduate degree from the University of Vermont and his law degree from the Washington College of Law of the American University, Washington, D.C. After law school, Mr. Sheppard served as a prosecutor in Vermont and New York City.

Hope M. Shoulders is a licensed attorney in the State of New Jersey who has recently completed a FATCA project for Aetna and worked for General Motors, National Transportation Safety Board, and the Department of Commerce. She completed her LL.M. in international Taxation from Thomas Jefferson School of Law in San Diego, California. She is a contributor to the Lexis publication Anti-Money Laundering, Asset Forfeiture, and Recovery, and to Lexis’ Guide to FATCA Compliance. She completed her international tax LL.M. thesis on the topic of transfer pricing issues with business restructuring, earned her J.D. and her MBA from the University of Tennessee and a Bachelors of Science in Sociology from the University of Virginia. She is a publication adjunct faculty member of Texas A&M University School of Law and at Thomas Jefferson School of Law’s Graduate International Taxation Program.

Dr. Garry Stone is a partner at PricewaterhouseCoopers LLP (“PwC”) and is the global leader of the Transfer Pricing Group. Dr. Stone is based in Chicago and has directed and performed numerous analyses of intercompany pricing and economic valuation issues for Fortune 500 size companies. Dr. Stone has performed projects in the automotive, banking, chemical, computer hardware and software, cosmetics, distribution, electrical controls and equipment, financial markets, food processing, heavy and industrial equipment, medical supplies, mining, pharmaceuticals, plastics, retailing, semiconductor, and telecommunications industries. He received a B.S. in Economics from Bowling Green State University, an M.A. in Economics from and his Ph.D. in Economics (Finance Minor) from The Ohio State University.

Rizwan Syed is a Transfer Pricing professional with PwC. Mr. Syed is based in Chicago and is a graduate of Ohio State University’s Moritz College of Law, where he received his JD; and Case Western Reserve University, where he received degrees in Economics and Political Science. His work with PwC focuses primarily on assisting clients in analyzing the arm’s length nature of their intercompany transactions for both compliance and planning purposes. Mr. Syed’s experience includes assisting clients with addressing transfer pricing-related regulatory requirements in various jurisdictions, including the U.S. and countries in Europe, Asia, and South America. Notably, he has extensive experience in assisting clients with preparation of transfer pricing documentation as required by U.S. transfer pricing law and the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, including assistance with preparation of comparables analysis.

Cameron Taheri is a Senior Manager in KPMG’s Transfer Pricing Dispute Resolution Group. He specializes in resolving transfer pricing disputes on behalf of multinational corporations, including Advance Pricing Agreements, Competent Authority settlements, and Examination and Appeals. Previously, Cameron was a Team Leader in the Advance Pricing and Mutual Agreement Program (APMA) at the Internal Revenue Service and began his transfer pricing career at Ernst & Young LLP. Cameron has a B.A. from the University of Texas and his J.D. from Northeastern University School of Law.

Debora De Souza Correa Talutto is the International Transfer Pricing Manager at Temenos Banking Software Co., and formerly a tax consultant at Deloitte/Brazil. Mrs. Correa-Talutto is the author of the Brazilian chapter in the Lexis publication Foreign Tax and Trade Briefs, the Brazilian chapter of LexisNexis’ Guide to FATCA Compliance, as well as the Brazilian chapter for the Lexis Anti Money Laundering, Asset Forfeiture, and Recovery publication. Mrs. Correa Talutto is pursuing her Doctorate in Juridical Science (S.J.D) in International Taxation at University of Florida. She holds a LL.M. in International Tax from University of Florida, a MBA, a post-graduate degree in Brazilian taxation, and an LL.B. (Brazil). She is a professor of the transfer pricing concentration at Thomas Jefferson School of Law’s Graduate International Taxation Program, and also an adjunct professor for the transfer pricing curriculum of Texas A&M University School of Law.

David R. Tillinghast is Of Counsel in the New York office of Baker & McKenzie LLP. His practice includes the tax aspects of domestic and international transactions, including mergers and acquisitions, securities offerings, investment funds, joint ventures and leasing, project and other types of financings, as well as transfer pricing and related issues. Mr. Tillinghast served as a member of the Permanent Scientific Committee of the International Fiscal Association from 1983 to 2000 and as its Chairman from 1995 to 2000. Mr. Tillinghast is a graduate of Brown University and Yale Law School. In 1996, the New York University School of Law Masters Program in International Taxation established in his honor the David R. Tillinghast Lectures on International Taxation.

Emin Toro is a partner in the law firm of Covington & Burling LLP. His practice concentrates on controversies involving multinational corporations. He received a B.A., summa cum laude, from Palm Beach Atlantic College in 1997, and a J.D., with Highest Honors, from the University of North Carolina at Chapel Hill in 2000, where he was an editor of the North Carolina Law Review. Mr. Toro served as a law clerk to Justice Clarence Thomas of the U.S. Supreme Court (2002–2003) and to Judge Karen LeCraft Henderson of the U.S. Court of Appeals for the D.C. Circuit (2000–2001).

Reeves C. Westbrook is a partner in the law firm of Covington & Burling LLP and co-chair of its tax practice group. His practice concentrates on controversies involving multinational corporations. He received a B.A., magna cum laude, from Vanderbilt University in 1971, and a J.D. from Yale University in 1974. Mr. Westbrook is a vice-chair of the taxation section of the International Bar Association.

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