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David Abbott

Mayer Brown

1675 Broadway
New York, NY 10019-5820
US
Tel: +1 212 506 2642
Fax: +1 212 849 5642
Email: dabbott@mayerbrown.com
Website: www.mayerbrown.com

David Abbott is a highly respected tax litigator and transactional lawyer. He advises clients across a broad range of critical issues, with a particular focus on key areas of corporate concern involving tax litigation.

David's dispute resolution practice emphasises tax litigation and controversy, as well as bankruptcy disputes. He has experience with tax audits and appeals, and represents clients before the US Tax Court and the US Court of Federal Claims. David's current and past cases involve corporate acquisition-related issues, payment of acquisition-related fees and financing-related issues such as debt versus equity characterisations, debt/equity swaps, transfer pricing and tax treatment of leasing transactions, including LILOs and SILOs. In addition, David has represented equity investors in chapter 11 bankruptcy cases involving several leading airlines with respect to aircraft lease tax indemnity agreement claims.

Straddling his tax litigation and transactional work, David has extensive experience with valuations of business enterprises plus tangible and intangible assets. He works regularly with valuation experts to document and justify appraisal conclusions and present or defend them in tax audits and litigation.

On the transactional side, David represents equity investors, lenders and lessees in equipment and real estate leasing transactions such as sale-leasebacks, leveraged and single-investor leasing, cross-border lease arrangements, acquisition and divestiture of leasing portfolios and leasing subsidiaries and related tax-oriented financing structures and debt instruments. His transactional tax counsel also encompasses acquisitions and divestitures, financial products, consolidated return regulations, general corporate taxation and partnership taxation.

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."


J Bradford Anwyll

PwC

600 13th Street NW, Suite 1000
Washington, DC 20005
US
Tel: + 1 202 414 4326
Email: brad.anwyll@us.pwc.com
Website: pwc.com/taxcontroversy

J Bradford Anwyll is a principal in the transfer pricing group of the firm's National Tax Services practice. Brad has more than 30 years of experience in tax controversy and litigation matters involving federal and international issues. He has participated in numerous cases before the Internal Revenue Service's Advance Pricing & Mutual Agreement Programme, Examination Division, and Appeals Office and has litigated more than 30 cases before the US Tax Court, the US Court of Federal Claims, the Federal District Courts, and the US Courts of Appeals. Brad has represented clients from a variety of industries including telecommunications, consumer products, oil and gas, pharmaceutical, and chemical manufacturing.

Brad has been recognised as one of the country's leading tax controversy and litigation practitioners by International Tax Review's Tax Controversy Leaders (2013-2015), Chambers USA for National Tax Litigation 2008, the Legal 500 for Tax Controversy 2007, and Washington, DC Super Lawyers 2007.

Brad is a fellow of the American College of Tax Counsel and a member of the Section of Taxation of the American Bar Association, where he served as a member of the Tax Court Appointments Committee and as chair of the Court Procedure and Practice Committee. He also is a member of the Federal Circuit Bar Association and the Court of Federal Claims Bar Association, where he served as chair of the Tax Section.

Brad has written a number of articles on tax controversy issues and was co-author of the 1999-2003 Cumulative Supplements to Litigation of Federal Civil Tax Controversies (Warren, Gorham & Lamont, 2d edition, 1997). He also is a frequent speaker at national tax conferences and seminars.

Brad received his JD, with distinction, from the Duke University School of Law and a BA, with University and Departmental (economics) Honours, from Johns Hopkins University. After leaving law school, Brad was a judicial clerk to the Honourable Marion T. Bennett of the US Court of Appeals for the Federal Circuit.


Gregory Barton

PricewaterhouseCoopers

1 North Wacker Drive
Chicago, IL 60606
US
Tel: +1 312 298 6084
Email: greg.barton@us.pwc.com
Website: pwc.com/taxcontroversy

Gregory L Barton is a principal in PwC's national transfer pricing practice. He has significant controversy and planning experience pertaining to transfer pricing, licensing, cost sharing arrangements, and other cross-border movement of tangible and intangible property and services. Greg also has extensive experience with advance pricing agreements, competent authority negotiations, and mediation. His controversy experience includes audits, administrative appeals, and litigation of federal tax disputes, with emphasis on transfer pricing of tangible and intangible goods and services, and litigation and controversy experience with respect to related issues such as penalties, documentation and summonses. He has also handled several audits and appeals in recent years involving transfer pricing with respect to intercompany financing transactions and structures, including debt/equity and interest rate controversies. Recently, Greg has helped a US-based client organise and centralise all of its worldwide tax controversy and compliance functions into its headquarters.

Relevant recent industry experience includes controversies in the pharmaceutical and medical device industries, as well as in branded consumer foods, semiconductors, chemicals, automobile parts, and high value services transactions.

Before joining PwC in 2011, Greg was a partner at Mayer Brown in Chicago, where he practised law for 24 years. He is a member of the Illinois bar; US Tax Court; and the US Court of Federal Claims. He received his JD with honours from the University of Chicago Law School. He also holds an MS in computer science from the University of Southern California, where he did work in the field of public key cryptography, and a BS in electrical engineering (summa cum laude) from the University of Notre Dame. Greg clerked for Judge Richard Posner on the US Court of Appeals in Chicago, and was an attorney at the White House Budget Office before joining Mayer Brown.


Howard Berman

Deloitte Tax

1633 Broadway
New York, NY 10019
US
Tel: +1 212 436 2242
Email: hberman@deloitte.com
Website: www.deloitte.com

Howard is a member of the Deloitte Tax (Deloitte US) controversy services team. Howard specialises in representing clients before the Internal Revenue Service (IRS) and in coordinating complex IRS examinations and appeals for multinational corporations. Howard has significant experience handling inbound and outbound transfer pricing matters, was one of the first practitioners to use alternative dispute resolution (ADR) techniques (that is, third party mediation) with the IRS and regularly uses fast-track settlement and other ADR techniques to negotiate the resolution of complex tax disputes for his clients.

In addition to transfer pricing issues, Howard has helped clients resolve issues surrounding the treatment of debt financing structures, the allocation of interest and other deductions to US source activities, the determination and computation of taxpayers' subpart F income and the correct information reporting of transactions between US and related foreign entities. For more than 20 years, Howard has represented clients in a variety of industries, including financial services, heavy manufacturing, pharmaceuticals, media and retail.

Howard served as a senior trial attorney for the US Department of the Treasury, and represented the IRS before the United States Tax Court. While representing the IRS, Howard served as industry counsel for the financial services and LBO/merger and acquisition industries. In his tenure at the US Department of the Treasury, Howard helped to develop the Coordinated Examination Programme, and, in that capacity, advised many IRS agents and appellate officers with respect to the development of cases and the resolution of technical issues.

Howard also has significant experience in IRS practice and procedure, penalty and quality control issues and has spoken and written extensively with respect to numerous IRS practice and procedure issues. Howard has a JD from the State University of New York at Buffalo – Faculty of Law and Jurisprudence, and a BA from Brandeis University.


Kevin Brown

PwC

600 13th Street, NW, Suite 1000, Washington, DC 20005-3333
US
Tel: +1 202 346 5051
Email: kevin.brown@us.pwc.com
Website: pwc.com/taxcontroversy

Kevin Brown is the co-leader of PwC's Washington National Tax Services' US tax controversy and regulatory services team. Kevin joined PwC after several notable professional roles, including stints as acting commissioner of the IRS and chief operating officer (COO) of the American Red Cross.

In his nine years at the IRS, Kevin worked in a number of positions. Most significantly, he served as the acting commissioner, where he managed more than 100,000 IRS employees responsible for a budget of $12 billion and the collection of more than $2.2 trillion dollars, approximately 95% of all federal revenues.

Other roles held by Kevin at the IRS included: deputy commissioner for services and enforcement, where he was responsible for the four IRS operating divisions, as well as all staff and activities related to IRS audits, collections, investigations, and service delivery, including telephone operations and returns processing; commissioner of the Small Business/Self-Employed (SB/SE) Division, where he oversaw excise, estate and gift, and employment tax for more than 45 million small business and self-employed taxpayers, and managed Bank Secrecy Act examinations on behalf of the IRS; principal adviser and chief-of-staff for former IRS Commissioner, Mark Everson; as well as division counsel for the SB/SE Division and assistant to former IRS commissioner, Charles Rossotti. Kevin's career also includes experience in the US Department of Justice, Tax Division, where he served as counsel to the assistant attorney general, and as a trial attorney who argued more than 50 cases in United States courts of appeals.

While at PwC, Kevin has represented clients in a broad range of matters, including IRS audits, appeals and obtaining administrative guidance. In particular, he has helped a number of companies enter into pre-filing agreements – thereby affording them certainty that their return positions will not be subject to later challenge on audit. In addition, Kevin led a coalition of insurance companies in securing an industry-wide resolution allowing them greater latitude in their treatment of impaired securities. More recently, he led another insurance industry coalition that obtained a safe harbour regarding the treatment of hedging gains and losses associated with variable annuities.

Kevin earned his JD, cum laude, from Boston College Law School and his BA, cum laude, from Hamilton College. He is a member of the Massachusetts and District of Columbia bar associations.


Cabell Chinnis

Mayer Brown

Two Palo Alto Square, Suite 300
3000 El Camino Real
Palo Alto, CA 94306-2112
US
Tel: +1 650 331 2020
Fax: +1 650 331 4520
Email: cchinnis@mayerbrown.com
Website: www.mayerbrown.com

Cabell Chinnis specialises in audits and appeals, especially in the contentious area of transfer pricing. He has obtained speedy and favourable results by identifying key issues in the case and resolving them. He also has significant experience in advance pricing agreements and tax treaties.

In audit, Cabell provides advice on working with the exam teams in special situations, preparing executives and other business personnel for interviews by the IRS or their experts, coordinating presentations to the exam team and resolving discovery disagreements with the exam team or Department of Justice. Cabell has successfully advised clients on how best to escalate within the IRS to senior agency personnel to facilitate resolution of audit issues. In appeals, Cabell specialises in handling complex matters and expediting resolution of issues if they are more limited in scope. His cases since January 1 2013 have involved section 482 issues in a variety of areas (services, tangible goods, transfers of intangibles), valuation disputes, R&E credit, and section 199.

Cabell also handles tax-related alternate dispute resolution, including fast-track and 'limited issue' audits. In addition, he counsels tax exempt entities on a full range of matters, including their organisation, operation and sponsorship.

Cabell began his nearly 30-year career by serving as a judicial clerk at the US Supreme Court for The Hon. Louis Powell, Jr.

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."


Kerwin Chung

Deloitte Tax LLP

555 12th Street, NW, Suite 400
Washington, DC 20004
US
Tel: +1 202 879 3108
Fax: +1 202 661-1126
Email: kechung@deloitte.com
Website: www.deloitte.com

Kerwin Chung is the managing principal of Deloitte Tax LLP's Washington National Tax Office transfer pricing team, and leader of Deloitte's national advance pricing agreement (APA) and mutual agreement procedure (MAP) group. Kerwin has more than 20 years' transfer pricing experience, specialising in APAs, MAPs, planning, examinations, and customs matters. His clients include US and foreign-based multinationals in numerous industries, including apparel, automotive, biotech, chemicals, computers, electronics, energy, food and beverage, industrial machinery, internet, logistics, office products, pharmaceuticals, professional services, publishing, semiconductors, software and telecommunications.

Kerwin's practice has involved complex transfer pricing issues, including a bilateral APA and rollback for a pharmaceutical company that resulted in the withdrawal of a more than $100 million IRS transfer pricing adjustment and penalty assessment; a bilateral APA covering cost sharing PCTs [platform contribution transactions] and CSTs [cost sharing transactions] for a software company; and bilateral APAs and competent authority representations with respect to inbound and outbound intercompany license transactions in several industries.

Kerwin has coauthored numerous publications, including Seeking efficiencies in the new IRS APA and MAP programmes, International Tax Review (November 2011); Competently negotiating the US competent authority process, 59 Tax Executive No. 3, (May/June 2007); and Transfer Pricing Rules and Compliance Handbook, (CCH 2006).

Kerwin has been included in Euromoney's Guide to the World's Leading Transfer Pricing Advisers since 2002 and in International Tax Review's Tax Controversy Leaders. He is an active member of the ABA Tax Section Transfer Pricing Committee, having moderated a panel on transfer pricing in a down economy issues in 2009 and presented on a panel discussing the IRS APA programme in 2011.

He has a JD (cum laude) from Harvard Law School and a BBA in accounting and real estate from the University of Hawaii. Kerwin has been admitted to the New York Bar and the District of Columbia Bar.


Kenneth Clark

Fenwick & West

Silicon Valley Center
801 California Street
Mountain View, CA 94041
US
Tel: +1 650 335 7215
Email: kclark@fenwick.com
Website: www.fenwick.com

Kenneth Clark is a partner in the Tax group of Fenwick & West and chairs its tax litigation practice. Fenwick has received numerous accolades for its tax controversy practice, including recognition by International Tax Review as US tax litigation firm of the year in three different years. The principal focus of Ken's practice is complex federal tax litigation and tax controversy work. He regularly practises in the United States Tax Court and has published a number of articles relating to tax controversies. Fenwick & West has worked on more than 70 federal tax litigations.

Ken has worked on numerous high profile tax controversy matters, for clients such as Xilinx, The Limited, Limited Brands, Textron, Daimler, GM Trading, Dover Corporation, Adaptec, Analog Devices, and CBS.

With more than three decades of experience, Ken has also managed a variety of complex commercial disputes in a number of foreign countries and more than 20 states. Litigation prevention and alternative dispute resolution (ADR) have also been important parts of his practice. He has served as Fenwick & West's ADR coordinator, as an American Arbitration Association arbitrator, and has been involved in numerous mediations and arbitrations.

Ken received a BA from the University of Redlands, where he graduated summa cum laude, and was first in his class. He received a JD from New York University School of Law, cum laude, and was a member of that school's Law Review. Ken also received an MBA from the University of California at Berkeley. He has extensive experience in teaching speaking techniques.

Ken is a member of the state bars of California and New York and is admitted to practice in numerous federal courts.


Ward Connolly

PwC

488 Almaden Boulevard
San Jose, CA 95110
US
Tel: +1 408 817 8234
Email: ward.connolly@us.pwc.com
Website: pwc.com/taxcontroversy

Ward Connolly is a principal in PwC's national tax services group and is resident in the firm's Silicon Valley Technology Center of Excellence in San Jose, California. Ward leads PwC's advance pricing, mutual agreement and transfer pricing controversy practice in the West Region of the United States. Ward has more than 18 years of experience as a tax professional and has represented US and foreign multinational corporations in complex tax audits, administrative disputes (IRS Appeals), alternative dispute resolution (fast track), advance pricing agreements (APAs) and litigation.

Ward has been recognised as one of the world's leading tax controversy advisers by International Tax Review and one of the best lawyers in the San Francisco Bay Area by Bay Area Lawyer Magazine. Ward has also been recognised in International Tax Review's World Tax for his skills in transfer pricing, where he has extensive experience with the issues faced by clients in the high-tech, biotech, and pharmaceutical industries.

Before joining PwC, Ward was a partner at Fenwick & West. Ward was previously a faculty member in the Department of Economics at Trinity University.

Ward earned his JD, with honours, from Duke University, and his PhD in economics and his BA from the University of South Carolina. Ward is a member of the California Bar Association and has authored many technical articles for trade journals and other publications. Ward frequently speaks for professional tax groups, including numerous chapters of the Tax Executives Institute and BNA/CITE, and has instructed a class on transfer pricing controversy for San Jose State University.


Daniel Dumezich

Deloitte Tax LLP

111 South Wacker Drive
Chicago, IL 60606
US
Tel: +1 312 486 5167
Email: ddumezich@deloitte.com
Website: www.deloitte.com

Daniel Dumezich is the managing director of federal tax controversy services at Deloitte Tax LLP. Before joining Deloitte Tax, Daniel was in the private practice of law for 26 years, including a four year term as the chair of the federal tax controversy practice at a major international law firm.

During his practice of law, Daniel has tried cases in the US Tax Court involving §482 reallocations and subpart F issues. He has also tried matters involving the deductibility of interest expense relating to a debt versus equity characterisation, a debt-equity swap, and capitalisation versus current deductibility of expenditures. Acquisition-related issues he has tried include valuation of assets and tax advantaged structuring.

Outside of litigation, Daniel has settled cases favourably for his clients, including his representation of 980 former partners of a large professional firm in a case in which the IRS sought more than $450 million in taxes – the matter settled for approximately five percent of that amount. He has achieved similar results for major financial institutions including banks, hedge funds, insurance companies and individuals involved with tax advantaged transactions deemed abusive by the IRS. Also he has represented clients on income and withholding tax matters.

Daniel served as a judge in Indiana and in Indiana's General Assembly as a state representative. He is also a frequent speaker on various tax controversy topics for a variety of organisations.

Daniel received a bachelor of business administration with a major in accounting in 1982 from Western Michigan University and a master of science in taxation in 1985 from DePaul University. He received a juris doctor with highest distinction in 1989 from the John Marshall Law School.


David Forst

Fenwick & West

Silicon Valley Centre
801 California Street
Mountain View, CA 94041
US
Tel: +1 650 335 7254
Email: dforst@fenwick.com
Website: www.fenwick.com

David Forst is the practice group leader of the tax group of Fenwick & West where he focuses on international corporate taxation. David is included in the Legal Media Group's Guide to the World's Leading Tax Advisers, published by Euromoney. He is also in Law and Business Research's International Who's Who of Corporate and Tax Lawyers (for the last five years). David is listed in Chambers USA's America's Leading Lawyers for Business (2011-2014), and has been named a Northern California 'Super Lawyer' in tax by San Francisco Magazine. David is a lecturer at Stanford Law School on international taxation where he has taught Stanford's international tax course for a number of years.

Fenwick & West has served as counsel in more than 150 large-corporate IRS Appeals proceedings and more than 70 federal tax court cases. Seven Fenwick tax partners appear in International Tax Review's Tax Controversy Leaders Guide. Fenwick was named US (or Americas) Tax Litigation Firm of the Year three times at ITR's annual America's Awards dinners.

Much of our tax dispute resolution work has involved transfer pricing. Fenwick & West is first tier in ITR's World Transfer Pricing (2015). Five Fenwick tax partners have appeared in Euromoney's Guide to the World's Leading Transfer Pricing Advisers. Transfer pricing cases in which we have been involved include: Apple Computer, Xilinx, DHL, LimitedBrands, among others. The vast majority of our transfer pricing cases have been resolved in Appeals, some on a "no change" basis.

Other cases in which we've represented clients in federal tax litigation matters include those that involved Sanofi, CBS, Analog Devices, Dover, Chrysler, Textron, Johnson Controls, Del Commercial, Illinois Tool Works, VF, S.C. Johnson, Intel, CMI Int'l, Laidlaw, Hitachi, Union Bank, GM Trading, and many more.


James Fuller

Fenwick & West

Silicon Valley Center
801 California Street
Mountain View, CA 94041
US
Tel: +1 650 335 7205
Fax: +1 650 919 0942
Email: jpfuller@fenwick.com
Website: www.fenwick.com

Jim Fuller is a partner in the tax group at Fenwick & West in Mountain View, California. He is one of the world's top 25 tax advisers, according to Euromoney. Fuller is described as one of the three "most highly regarded" US tax practitioners in Law Business Research's Who's Who Legal (2015), and is the only US tax adviser to receive a coveted Chambers 'star performer' rating (higher than first tier) in Chambers USA (2015).

Fuller and his firm have served as counsel in more than 150 large-corporate IRS Appeals proceedings and more than 70 federal tax court cases. Seven Fenwick tax partners appear in International Tax Review's Tax Controversy Leaders Guide. Fenwick has been named US (or Americas) Tax Litigation Firm of the Year three times at ITR's annual Americas Awards Dinners.

Two of our tax partners were shortlisted by Euromoney at its Women in Business Law Awards dinners in the America's Leading Lawyer for Tax Dispute Resolution category. One is a two-time winner of the award.

Much of our tax dispute resolution work has involved transfer pricing. Fenwick & West is first tier in ITR's World Transfer Pricing (2015). Five Fenwick tax partners have appeared in Euromoney's World's Leading Transfer Pricing Advisers. Transfer pricing cases in which we have been involved include: Apple Computer, Xilinx, DHL, and LimitedBrands, among others. The vast majority of our transfer pricing cases have been resolved in Appeals, some on a 'no change' basis.

Other cases in which we've represented clients in federal tax litigation matters include those that involved Sanofi, CBS, Analog Devices, Dover, Chrysler, Textron, Johnson Controls, Del Commercial, Illinois Tool Works, VF, S.C. Johnson, Intel, CMI Int'l, Laidlaw, Hitachi, Union Bank, GM Trading, and others.


Jennifer Fuller

Fenwick & West

Silicon Valley Center
801 California Street
Mountain View, CA 94041
US
Tel: +1 650 335 7284
Email: jfuller@fenwick.com
Website: www.fenwick.com

Jennifer Fuller is a senior partner in the tax group at Fenwick & West in Mountain View, California. She was included for the fifth time as one of the world's top 25 women tax advisers in Euromoney's guide to the world's leading women business lawyers (2015).

Jennifer was named 'America's Best in Tax Dispute Resolution' by Euromoney at its 2014 and 2015 Americas Women in Business Law awards dinner. She also has been on Euromoney's Women in Business Law shortlist three times for the award 'Best in Tax'.

Jennifer's work during 2015 included large-corporate tax litigation and M&A matters, including work on some of the recent and widely publicised inversion transactions.

Jennifer is on the Executive Leadership Committee of the International Fiscal Association, which is a highly-regarded worldwide association of leading tax advisers, and has appeared regularly in Euromoney's guide to the world's leading tax lawyers.

Jennifer has served as the Northern California chair for the California State Bar International Tax Committee. She has spoken at and chaired numerous seminars on international tax subjects. Jennifer's articles have appeared in Tax Notes International magazine and in Tax Notes magazine.

Whittier College awarded Jennifer its Alumna Achievement Award in 2013 "for superior accomplishments in her career". Later that year, Jennifer was elected to serve on the Whittier College Board of Trustees, a position she still holds.

Jennifer has been a tax partner at Fenwick for more than 20 years, and plays an instrumental role in the firm's tax practice. The firm has represented six of the Fortune top 10 companies, more than 50 of the Fortune 100 and more than 100 of the Fortune 500 companies in federal tax matters.

Jennifer has also been included in Euromoney's Guide to the World's Leading Tax Advisers, Law and Business Research's International Who's Who of Corporate Tax Lawyers, ITR's Leading Lawyers in the Western US, Euromoney's Guide to the Leading US Tax Lawyers, and International Tax Review's Best Tax Advisers in North America.


John Hildy

Mayer Brown

71 S Wacker Drive
Chicago, IL 60606
US
Tel: +1 312 701 7769
Fax: +1 312 706 8785
Email: jhildy@mayerbrown.com
Website: www.mayerbrown.com

John has represented taxpayers in all stages of federal tax controversy, including pre-audit, audit, administrative appeals, and litigation. He is also experienced in representing taxpayers during IRS fast-track proceedings and in court-supervised mediation. John has also advised taxpayers in connection with competent authority negotiations, advance pricing agreements, and other tax treaty matters.

John's practice focuses heavily on defending and structuring transactions with significant transfer pricing implications, including cross-border transfer pricing of tangible and intangible property, shared headquarter services, and cost sharing arrangements. He has advised both US taxpayers with respect to international tax implications of offshore operations (for example, subpart F manufacturing, section 936), as well as non-US taxpayers with respect to the implications of their US activities.

John has extensive experience defending against civil and criminal tax penalties and in addressing evidentiary privileges in the tax controversy context, including the attorney client privilege and work product protection in the modern business environment in light of IRS policies concerning tax accrual work papers and FASB Interpretation (FIN) No 48.

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."


Charles Hurley

Mayer Brown

1999 K Street, NW
Washington, DC 20006-1101
US
Tel: +1 202 263 3260
Fax: +1 202 263 5260
Email: churley@mayerbrown.com
Website: www.mayerbrown.com

Chuck Hurley's practice is concentrated primarily on matters of tax-related litigation and advice. His professional experience includes more than 13 years' service (1990–2003) with the US Department of Justice's Tax Division, where he was responsible for preparing and conducting significant tax trials involving document-intensive, complex disputes. Chuck held first chair on two of the tax division's most prominent recent cases: Long-Term Capital Holdings v. United States and Trigon Insurance Co. v. United States.

In addition, Chuck served as first chair on more than 20 other jury and bench trials dealing with tax-related issues. He was also lead counsel on numerous other cases that were resolved short of trial, and he handled numerous evidentiary hearings regarding injunctions and summons enforcement proceedings. Recently, Chuck has represented Eaton, Siemens, TIAA-CREF and Cargill, to name a few.

Before working with the Department of Justice, Chuck held positions with two other prominent law firms. Earlier, he served as law clerk to The Honorable Alvin Krenzler, US District Court for the Northern District of Ohio. Since joining Mayer Brown in 2003, Chuck has focused on complex, document-intensive tax matters with the potential to be litigated.

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."


Cynthia Hustad

Deloitte Tax LLP

555 Mission Street
San Francisco, CA 94105-0920
US
Tel: +1 415 783 5567
Fax: +1 415 783 8962
Email: chustad@deloitte.com

Cindy Hustad is the Deloitte Tax LLP (Deloitte US) West Region tax controversy competency leader and represents corporate clients before the IRS. During her 15-year tenure at Deloitte, Cindy has successfully represented many large and small clients, both at the examination and appeals levels, specialising in transfer pricing and international issues. Before joining Deloitte, Cindy was a special trial attorney with the IRS Chief Counsel's Office where she represented the IRS in US Tax Court in upwards of 50 litigated cases. During her period at the IRS, Cindy also advised large case agents, international examiners, and appeals officers in some of the largest examinations undertaken by the IRS involving a wide range of complex international and domestic corporate issues. Cindy also represented the government in litigating several large corporate tax and transfer pricing cases, including DHL v. Commissioner. Cindy has also held the position of law clerk at the United States Court of Appeals for the Ninth Circuit, while other positions held include acting assistant professor at the New York University Law School.

Cindy is admitted to the state bar of California, holds an admission to practice at the US Tax Court and is a past president of the San Francisco Tax Litigation Club. She was also the recipient of the IRS Chief Counsel National Litigation Award in 1997.

Cindy holds a BA from the University of Wisconsin, a JD from the University of Wisconsin Law School and achieved her LLM (tax) at the New York University Law School.


Sharon Katz-Pearlman

KPMG

345 Park Avenue
New York, NY 10154
US
Tel: +1 212 872 6084
Fax: +1 212 409 8270
Cell: +1 917 533 3375
Email: skatzpearlman@kpmg.com
Website: www.kpmg.com

Sharon Katz-Pearlman is the national principal-in-charge of KPMG's tax dispute resolution network in the US. She also serves as KPMG International's head of global tax dispute resolution and controversy, overseeing a network of dispute resolution specialists from KPMG's member firms.

Sharon advises clients during all phases of the disputes continuum, from pre-dispute (for instance, audit readiness, voluntary disclosures and pre-filing assistance) through examination, appeals and alternative dispute resolution (ADR) processes. With more than 25 years of experience in the field, Sharon works with clients on all aspects of their IRS matters, dealing with a wide variety of domestic and international tax issues.

Sharon's US practice focuses primarily on representation before the IRS, of multinational corporate clients and financial institutions, both domestic and international. She provides assistance in all facets of alternate dispute resolution (ADR), including pre-filing agreements, early referral and mediation, as well as traditional examination and appeals consulting. Sharon advises on disputes involving a wide range of technical issues including domestic corporate reorganisations, TEFRA matters, competent authority proceedings and transfer pricing issues.

Before joining KPMG, Sharon was a special litigation attorney with the IRS Office of Chief Counsel, Manhattan District Counsel, advising many exam and appeals teams on varied issues. She was also responsible for the development and litigation of major tax matters before the US Tax Court and served on a number of litigation teams. While with the IRS, Sharon received the National Attorney of the Year award (the James Markham Memorial Award), presented annually to one field attorney in the country, for outstanding contribution to the Office of Chief Counsel.

Sharon is a frequent presenter at tax conferences and has published a variety of industry articles on various domestic and international tax topics.


John Keenan

Deloitte Tax LLP

555 12th St NW Ste 400
Washington, DC 20004-1207
US
Tel: +1 202 879 5605
Email: jkeenan@deloitte.com

John R Keenan is the managing director of the tax controversy group in the Washington National Tax Office of Deloitte Tax LLP.

In his role as a tax controversy specialist, John represents clients before the IRS Examination Division and IRS Appeals. John also assists clients on a wide range of procedural issues, such as statute of limitations, refund claims, and penalty issues as well as solving sensitive problems through strategic solutions. Before joining Deloitte Tax, John worked in Arthur Andersen's federal tax services office, specialising in tax controversy issues.

From 1988 to 1998, John served as a senior attorney in the IRS Chief Counsel's Office where he represented the IRS before the United States Tax Court and provided advice to IRS personnel on all matters incident to the assessment and collection of taxes. John also was appointed a special assistant United States attorney, which allowed him to represent the IRS in the United States Bankruptcy Courts.

John has a number of qualifications and memberships. He has been admitted to the District of Columbia Bar and the Tennessee Bar, and is admitted to practice in the United States Tax Court. He is a member of the Administrative Practice Committee of the American Bar Association, and a member of the IRS Advocacy and Relations Committee at the American Institute of CPAs (AICPA). John also frequently speaks to professional groups on IRS controversy and IRS practice issues.

He has a JD from the University of Memphis and a BA from Rutgers University.


Andrew Kim

Fenwick & West

Silicon Valley Center
801 California Street
Mountain View, CA 94041
US
Tel: +1 650 335 7146
Email: akim@fenwick.com
Website: www.fenwick.com

Andrew Kim is a partner in the tax group of Fenwick & West. His practice focuses on both domestic and international corporate tax matters, with an emphasis on tax dispute matters. Andrew served as counsel in CBSCorporation v. United States in the US Court of Federal Claims, and is now serving as counsel in Analog Devices, Inc. v. Commissioner in the US Tax Court.

Andrew appears in Euromoney's World's Leading Tax Advisers, International Tax Review's Tax Controversy Leaders, and Law Business Research's Who's Who Legal: Corporate Tax 2015.

Andrew has significant experience in representing clients with respect to cross-border transactions, corporate restructurings, international joint ventures, transfer pricing, as well as dispute resolution matters. He has published articles on international tax issues and developments in the Journal of Taxation, International Taxation, the Euromoney Corporate Tax Handbook, and World Tax. Andrew frequently speaks on international tax issues at meetings for professional tax groups, including the Tax Executives Institute and Bloomberg BNA.

Fenwick's tax practice has earned a reputation as one of the nation's leading domestic and international tax practices. Fenwick was named US (or Americas) Tax Litigation Firm of the Year three separate times by International Tax Review. Fenwick has also been recognised by International Tax Review as first tier in both its World's Leading Tax Planning Firms and World's Leading Transactional Firms surveys, and has been recognised as Americas M&A Tax Firm of the Year.

Andrew received his JD, cum laude, from Harvard Law School, and BS in psychology with highest honours from the University of Illinois.

Andrew is a member of the state bars of California and Illinois.


Thomas Kittle-Kamp

Mayer Brown

71 S Wacker Drive
Chicago, IL 60606
US
Tel: +1 312 701 7028
Fax: +1 312 706 9197
Email: tkittlekamp@mayerbrown.com
Website: www.mayerbrown.com

Since joining Mayer Brown in 1990, Tom Kittle-Kamp has represented clients in all phases of tax controversy and litigation. His litigation experience includes the trial and appeal of major corporate cases involving section 482 allocations, substance-over-form theories, intangible assets, debt-equity characterisation, valuation disputes, capitalisation questions, subpart F and other international tax issues, subchapter C issues, and leasing transactions. Tom also maintains an extensive practice of advising and representing clients with respect to administrative matters, including IRS audits, IRS appeals (including fast track and appeals mediation procedures) and competent authority negotiations. He also represents corporate clients with respect to tax-sharing disputes.

Tom has deep experience in all aspects of international transfer pricing, particularly matters involving intangible assets and intellectual property. He provides tax planning advice with respect to cross-border transactions involving intangible assets, goods and services; transfer-pricing documentation; and the development, exploitation and disposition of intangible assets, including licences, sales and cost-sharing arrangements. He is co-author of the treatise Federal Income Taxation of Intellectual Properties and Intangible Assets (Warren, Gorham & Lamont 1997), which is updated twice a year. Before law school, he worked for several years as a newspaper reporter.

According to Chambers USA, Tom is "extremely confident and persuasive in the courtroom and a pleasure to work with." According to Legal 500, Tom is "a very rare combination – a subtle courtroom advocate and a real tax expert".

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level.


Brian Kittle

Mayer Brown

1675 Broadway
New York, NY 10019-5820
US
Tel: +1 212 506 2187
Fax: +1 212 849 5987
Email: bkittle@mayerbrown.com
Website: www.mayerbrown.com

Since joining Mayer Brown, Brian Kittle has been a member of Mayer Brown's tax controversy and transfer pricing practice. Brian represents clients in all facets of tax controversy, including administrative proceedings, contested hearings, litigation and appellate matters. His controversy experience includes major corporate tax matters. Brian frequently assists clients in using IRS alternative dispute resolution initiatives, such as pre-filing agreements, and has broad experience handling audits and IRS appeals. Brian also has extensive experience defending against civil tax penalties and protecting taxpayers' evidentiary privileges, including the attorney client privilege and work product protection in the current business and IRS environment concerning tax accrual workpapers, in tax controversies. His litigation experience includes extensive trial work in various Federal Courts including the United States Tax Court, the United States Court of Federal Claims and several United States district courts, and appellate advocacy in various United States Courts of Appeals. Brian also has deep experience with all aspects of intercompany transactions. He has advised on intercompany financing arrangements as well as other tangible and intangible intercompany transfers of property. Before joining Mayer Brown, Brian began his career severing as law clerk and attorney adviser to Hon. Joseph Robert Goeke of the United States Tax Court from 2004 to 2006. Brian is regularly recognised as a leader and rising star in tax controversy and often speaks at conferences on tax controversy matters.

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 United States Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."


Kenneth Klein

Mayer Brown

1999 K Street, NW
Washington, DC 20006-1101
US
Tel: +1 202 263 3377
Fax: +1 202 263 5377
Email: kklein@mayerbrown.com
Website: www.mayerbrown.com

Kenneth Klein concentrates his practice on international taxation. His experience includes planning, structuring/restructuring, tax controversies, regulations, legislation, private letter rulings, and amicus briefs. He has represented domestic and international clients in numerous industries, including manufacturing, financial services, software, transportation, pharmaceuticals, services, real estate, agricultural, trading, and entertainment, among others.

Ken has experience with outbound investments, inbound investments, income bifurcation and amalgamation, controlled foreign corporations (subpart F), investments in US property, intangibles, contract manufacturing, source of income, foreign tax credits, transfer pricing, portfolio interest, conduit financing arrangements, withholding tax, tax treaties, investment funds, derivatives, and stock and securities lending.

Ken was co-chairman of Mayer Brown's tax transactions practice from 2006-2012. Before Mayer Brown, Ken worked at the IRS, first as attorney and then as assistant branch chief in the Legislation & Regulations Division and the General Litigation Division (1977-1981), and later as the Associate Chief Counsel (Technical) (1988-1990). Ken was an associate and then a tax partner at Cadwalader, Wickersham & Taft from 1981-1988 and 1990-2002. He was also a fellow of the American Society of International Law (1976-1977).

Ken is recognised year after year for his skills in international taxation. He has been lauded by clients for his "sophisticated cross-border tax planning, structuring and restructuring for a number of US and non-US multinationals". Legal 500 2015 refers to Ken as a "font of practical advice" and has named him a leading lawyer for five consecutive years. For the past seven years, Ken has been named among the World's Leading Tax Advisers (Euromoney/International Tax Review). He is recognised as a leading tax controversy adviser in the International Tax Review Tax Controversy Leaders guide and named among the 'Best Tax Lawyers' in Washington DC by Washingtonian Magazine and Washington Post Magazine. Ken has also been featured as a leading tax lawyer in Washington DC by Super Lawyers for five consecutive years. Mayer Brown's tax practice is ranked Tier 1 by Chambers USA, Legal 500 and the International Tax Review.

Ken is chair of the Washington International Tax Study Group, vice president of the Legal Aid Society of the District of Columbia and is on the board of visitors of the University of Georgia School of Law.


Larry Langdon

Mayer Brown

Two Palo Alto Square, Suite 300
3000 El Camino Real
Palo Alto, CA 94306-2112
US
Tel: +1 650 331 2075
Fax: +1 650 331 4575
Email: lrlangdon@mayerbrown.com
Website: www.mayerbrown.com

Attorney Larry Langdon brings comprehensive experience in the areas of tax controversy and planning to clients' service. He is widely recognised for his knowledge of federal tax policies and applications and has been characterised by Chambers USA as "a great tax mind".

Larry has been a speaker at the American Bar Association Section of Taxation, American Institute of CPAs, Manufacturers Alliance [MAPI], Tax Executives Institute and many other professional and industry groups.

Larry joined Mayer Brown in 2003. Previously, he held senior positions with the US Internal Revenue Service (commissioner, Large & Mid-Size Business division, 1999–2003; Legislation and Regulations division, Office of Counsel, 1964–1968; and Joint Committee division, Office of Chief Counsel, 1961–1962) and, in the private sector, with leading firms such as Hewlett-Packard (VP, general transition manager, 1999; VP, tax, licensing and customs, 1978–1999); Vetco (director of taxes and corporate secretary, 1976–1978); and the Ford Motor Company (senior tax attorney, General Counsel's Office, 1968–1976). Larry also worked with the CARE organisation from 1962–1964.

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."


Darrin Litsky

Deloitte Tax LLP

1633 Broadway
New York, NY 10019-6754
US
Tel: +1 212 436 5760
Fax: +1 212 653 7883
Email: dlitsky@deloitte.com

Trained as a lawyer and a certified public accountant (CPA), Darrin Litsky is a transfer pricing specialist in the New York office of Deloitte Tax LLP (Deloitte US). Darrin has a diverse background of 25 years of professional tax and accounting experience with industry, Big 4 public accounting, major law firms, and the Internal Revenue Service's (IRS) advance pricing agreement (APA) programme. While in industry, Darrin served as general tax counsel of a publicly owned telecommunications company and was responsible for its worldwide transfer pricing in more than 40 countries.

Darrin served as a team leader for four years with the IRS APA programme. Including his time in government practice, Darrin has been substantively involved in well over 100 APA requests involving a variety of different countries and industries, including telecommunications and insurance. His current transfer pricing practice is primarily APA request representation, mutual agreement procedure (MAP) matters, and audit defence.

Darrin is a recent past chairman of the Transfer Pricing Committee of the American Bar Association (ABA) Tax Section. Over the past 10-plus years, he served as the committee's chairman, vice chairman, led subcommittees on APAs, intercompany services, and other important developments, and received the committee's Outstanding Service Award for 2003/2004.

In 2014, Darrin led a ABA task force that provided formal comments to the IRS on proposed procedures for obtaining an advance pricing agreement. Similarly, in 2005, Darrin was responsible for leading the ABA's formal comments to the IRS on the operation of the APA programme. As part of this effort, he provided oral testimony on the APA programme in a public hearing held in Washington.

In 2004, Darrin led another ABA task force that provided formal comments on proposed Treasury Regulations for transfer pricing of intercompany services. In 2006, Darrin contributed to the ABA's comments on temporary Treasury Regulations for transfer pricing of intercompany services.

Darrin holds a BS economics degree (magna cum laude) from The Wharton School and a Juris Doctor degree from Georgetown University Law Center. He is a member of the District of Columbia Bar and a certified public accountant (CPA).


Mark Nehoray

Deloitte Tax LLP

555 W Fifth Street
Los Angeles, CA 90013
US
Tel: +1 213 688 4104
Email: mnehoray@deloitte.com
Website: www.deloitte.com

Mark Nehoray is a Deloitte Tax LLP senior partner, based in Los Angeles.

Mark is consistently recognised as a leading transfer pricing adviser by publications including International Tax Review and the Euromoney/Legal Media Group Guide to the World's Leading Transfer Pricing Advisers.

With more than 33 years of experience in tax and transfer pricing, Mark assists multinationals with transfer pricing studies restructuring of foreign royalties and other foreign income streams. Mark led the team that successfully negotiated Mexico's first ever transfer pricing ruling.

Mark is the transfer pricing adviser to three of the world's largest multinationals, and has conducted a significant number of transfer pricing studies across various industries (including entertainment and media, gaming, multi-level marketing, hi-tech, apparel, and non-profit). These projects have included both defensive work with respect to ongoing IRS audits and competent authority assistance, as well as planning studies and advance pricing agreements (APAs). Over the past 15 years, he has been responsible for Deloitte's largest APA, as well one of the largest multilateral APAs in the programme. He is currently assisting two large US-based multinationals with respect to their IRS transfer pricing examinations, another two US-based multinationals with respect to their unilateral APAs, as well as assisting 10 foreign-based multinationals with respect to their bilateral APAs.

Since 2002, Mark has been the executive producer and the host of Deloitte's Transfer Pricing Dbriefs, a monthly internet programme. He is a frequent speaker at US transfer pricing conferences sponsored by the BNA.

His recent publications include: Transfer pricing of intangibles – media and entertainment, International Tax Review (December 2013); Turning tech investments into value repositories, International Tax Review (February 2011); and How APAs fit into today's regulatory landscape, International Tax Review (May 2009).

Mark has a bachelor's degree in business administration and a master's degree in business taxation from the University of Southern California.


Larissa Neumann

Fenwick & West

Silicon Valley Center
801 California Street
Mountain View, CA 94041
US
Tel: +1 650 335 7253
Email: lneumann@fenwick.com
Website: www.fenwick.com

Larissa Neumann focuses her practice on US tax planning and tax controversy with an emphasis on international transactions. She has broad experience advising clients on acquisitions, restructurings and transfer pricing issues. She has successfully represented clients in federal tax controversies at the audit level, in appeals and in court.

Larissa appears as a rising star in Euromoney's "Guide to the World's Leading Tax Advisers". Euromoney selected Larissa for inclusion in the Americas Women in Business Law Awards shortlist for Best in Tax Dispute Resolution in 2014 and Rising Star: Tax, in 2015.

Larissa frequently speaks at conferences for professional tax groups, including the Tax Executives Institute, International Fiscal Association, Pacific Rim Tax Institute, Bloomberg, and the American Bar Association. She is the ABA International Law Tax Liaison.

Larissa has published several articles, including recently:

  • US Tax Overview, Euromoney's LMG Rising Stars 2015
  • US transfer pricing litigation update, International Tax Review (March 2015)
  • Areas of TP Scrutiny in a pre- and post-BEPS World, International Tax Review (February 2015)
  • US International Tax Developments, The Euromoney Corporate Tax Handbook 2015
  • US Transfer Pricing Developments, International Tax Review (2014)
  • US Tax Developments, International Tax Review (December/January 2013)
  • US International Tax Developments, The Euromoney Corporate Handbook 2012
  • Character and Source of Income from Internet Business Activities, The Contemporary Tax Journal (July 2011)
  • The Application of the Branch Rule to Partnerships, International Tax Journal (July – August 2010)

Fenwick has one of the world's top tax planning and tax transactional practices, according to International Tax Review (2014 and 2015) and is first tier in tax, according to World Tax 2015. International Tax Review gave Fenwick its San Francisco Tax Firm of the Year award a total of six times and its US Tax Litigation Firm award a total of three times. International Tax Review also named Fenwick its Americas M&A Tax Firm of the Year in 2012.


Kathryn Horton O'Brien

PwC

600 13th Street NW Suite 1000
Washington, DC 20005
US
Office: +1 202 414 4402
Mobile: +1 202 340 0416
Fax: +1 678 529 1375
Email: kathryn.obrien@us.pwc.com
Website: pwc.com/taxcontroversy

Kathryn is a principal in PwC's Washington National Tax Transfer Pricing practice. She is assisting clients with all aspects of transfer pricing: controversy risk management (including obtaining advance pricing agreements (APAs) and mutual agreement procedures (MAPs)), documentation, risk assessment, more efficient use of transfer pricing resources and planning. She is one of PwC's global BEPS 'champions'. In that role, she has been working with clients and the OECD to assess the impact of the initiative and develop solutions.

Before PwC, Kathryn was the global transfer pricing leader for GE. At GE, Kathryn

managed transfer pricing risks and opportunities (using APAs as one of many tools), oversaw documentation and controversies, coordinated global strategy, collaborated on customs solutions leveraging transfer pricing and teamed with the transfer pricing professionals and global tax professionals to help manage most of GE's intercompany transactions internally (financial and industrial).

Kathryn spent several years at EY before joining GE. There, she was the US national office leader for financial services transfer pricing and transfer pricing controversy matters, engaged in all aspects of transfer pricing. She was responsible for coordinating APAs and MAPs for clients at the National Office and coordinated financial services transfer pricing globally. In addition to the financial services sector, her clients were operating in the following industries/sectors: major fashion brands, high tech, consumer products, large international retailers, food and beverage importers, healthcare, utilities, entertainment, automotive and more.

Toward the beginning of her career, Kathryn helped launch the APA programme at the IRS. She acted in a management capacity within the programme, including acting director and team leader, and was recognised with the IRS's Attorney of the Year award in 1994, for her efforts with regard to the programme.

Kathryn is a frequent speaker at international conferences. She has worked closely with the OECD on all aspects of transfer pricing, particularly on documentation simplification, financial services, intangibles, PEs and most recently, BEPS and risk assessment.

She has an undergraduate degree in business finance, a JD and an LLM (in taxation). She is admitted to the DC and Pennsylvania Bars.


Shawn O'Brien

Mayer Brown

700 Louisiana Street
Suite 3400
Houston, TX 77002-2730
US
Tel: +1 713 238 2848
Fax: +1 713 238 4602
Email: sobrien@mayerbrown.com
Website: www.mayerbrown.com

Shawn O'Brien is a tax controversy partner in the Houston office. Shawn represents clients in all types of tax disputes with taxing authorities on international, federal and state levels. He routinely advises clients on various tax issues during tax examinations, in administrative appeals and as an advocate in trial and appellate litigation before the US Tax Court, US district courts and the US Court of Federal Claims. Shawn's tax controversy and litigation experience spans a broad range of areas, including transfer pricing controversies, debt versus equity issues, international withholdings, advance pricing agreements, tax shelter disallowances, estate and gift tax valuations, research and development tax credits, excise taxes, and changes in accounting methods.

Shawn advises foreign and domestic corporations, partnerships, MLPs, and LLCs seeking corporate and tax advice in connection with various types of foreign and domestic transactions, including mergers and acquisitions, restructurings, divestitures, leveraged buyouts, structured financings, and oil and gas transactions.

Shawn is particularly focused on a variety of tax issues facing the energy industry including tax controversy, restructuring, acquisition and disposition of energy assets. Shawn served as chairman of the committee for energy and natural resources of the State Bar of Texas Tax Section from 2011 to 2013.

Shawn is a certified public accountant (CPA) licensed in Louisiana.

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team...dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level".


Pam Olson

PwC

600 13th Street NW, Suite 1000
Washington, DC 20005
US
Tel: +1 202 414 1401
Fax: +1 678 529 1022
Email: pam.olson@us.pwc.com
Website: pwc.com/taxcontroversy

Pam is a US deputy tax leader and Washington National Tax Services leader of PwC. In her role with WNTS, Pam leads a team that includes many former senior government officials and policy advisers.

Before joining PwC, Pam led the Washington tax practice at Skadden, Arps, Meagher & Flom and served as assistant secretary for tax policy at the US Department of the Treasury.

Pam has represented clients in a broad range of matters, including IRS audits, appeals and litigation; congressional investigations; private letter ruling requests, proposed regulations, and other IRS and Treasury guidance; and in the legislative process. She has advised clients on tax and social security reform and on the structuring of financing, partnership, and M&A transactions. She is a frequent speaker on tax, economic and federal budget matters and has testified before several congressional committees, most recently before the Senate Finance Committee on international tax reform.

As assistant secretary for tax policy, Pam had supervisory responsibility for providing the secretary of the treasury with policy analysis and recommendations for all domestic and international issues of federal taxation, including legislative proposals, regulatory guidance, and tax treaties, and for providing the official estimates of all government receipts for the president's Budget and treasury cash management decisions. Pam also held positions with the chief counsel's office of the Internal Revenue Service as special assistant to the chief counsel, attorney-adviser in the Legislation and Regulations Division and trial attorney in San Diego District Counsel.

In 2000 and 2001, Pam was the first woman to serve as chair of the American Bar Association Section of Taxation. She has served as tax and economic adviser to two presidential campaigns and as tax adviser to the National Commission on Economic Growth and Tax Reform. She has been included repeatedly in Chambers USA: 'America's Leading Lawyers for Business' and 'The Best Lawyers in America' for tax law. Pam served as a regent of the American College of Tax Counsel and is on the board of several non-profit organisations. She received the Treasury Department's highest award, distinguished service awards from the Federal Bar Association and Tax Executives Institute, and delivered both the Lawrence Woodworth and Erwin Griswold annual lectures.

Pam received her BA, MBA, and JD from the University of Minnesota.


Edward Osterberg

Mayer Brown

700 Louisiana Street
Suite 3400
Houston, TX 77002-2730
US
Tel: +1 713 238 2666
Fax: +1 713 238 4656
Email: eosterberg@mayerbrown.com
Website: www.mayerbrown.com

Ed Osterberg is a tax transactions and consulting partner in Mayer Brown's Houston office. His extensive experience includes all areas of business income taxation, with emphasis on corporate and partnership taxation and international transactions. Ed has advised corporate and individual clients on the federal tax consequences of various transactions, including 1031 exchanges, mergers and acquisitions; tax-free reorganisations; corporate spin-offs and other divestitures; partnerships; foreign operations, including cross-border joint ventures with non-US partners; and inbound investment into the United States by non-US investors.

Chambers USA 2015 refers to Ed as "tremendous" and he is held in high regard for his expertise in international tax transactions. Chambers USA also says: "Ed Osterberg impresses the legal market with his grasp that goes beyond the technicalities of the matter, especially in international tax law, where he is extremely impressive, and in M&A, where he is a leading transactional lawyer."

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 United States Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level."


Kimberley Peterson

Deloitte Tax LLP

225 West Santa Clara Street
San Jose, CA 95113-2303
US
Tel: +1 408 704 4041
Fax: +1 408 704 8074
Email: kimpeterson@deloitte.com

Kim Peterson is a director in the Silicon Valley office of Deloitte Tax LLP's tax controversy services west region practice. During her seven year tenure at Deloitte, Kim has successfully represented many corporate and partnership clients before the IRS, both at the examination and appeals levels, throughout the US. Kim specialises in transfer pricing and other cross-border and international issues.

Before joining Deloitte, Kim spent 13 years with the IRS Chief Counsel's Office, as international field counsel, associate area counsel, and deputy area counsel for strategic litigation. While at the IRS, Kim advised large case agents, international examiners, and appeals officers in some of the largest examinations undertaken by the IRS, involving a wide range of complex international and domestic corporate issues. Kim also represented the IRS in the US Tax Court in large case litigation involving transfer pricing and other international issues, including in the DHL v. Commissioner and Microsoft v. Commissioner cases, receiving Western regional and national litigation awards. As associate area counsel and deputy area counsel for strategic litigation, Kim had responsibility for large case litigation, including the special trial attorney litigation of Xilinx v. Commissioner and Veritas v. Commissioner.

Kim is a member of the State Bar of California and is admitted to practice before the US Tax Court and the US Court of Appeals for the Ninth Circuit. Kim is a frequent speaker on IRS practice and procedure and the management of complex IRS examinations, especially transfer pricing examinations. In 2015 Kim became an instructor in tax practices, penalties and procedures in the San Jose State University master's in taxation programme. Kim received her BS in business administration from the University of California, Berkeley, and her JD from the University of Arizona, James E Rogers College of Law


Irving Plotkin

PwC

125 High Street
Boston, MA 02138
US
Tel: +1 617 530 5332
Email: irving.h.plotkin@us.pwc.com
Website: pwc.com/taxcontroversy

Irving H Plotkin, senior managing director of PwC's tax and economic controversy practice and a member of its national tax service based in Boston, is one of the premier experts in the field of transfer pricing and other complex domestic and international tax issues such as economic substance, financial products, and insurance.

He specialises in analysis of the effects of various types of government regulation, self–regulation, and taxation on capital flows, output, prices, risk–taking, competition, and efficiency within individual industries.

His work on risk/return measurement and on international and domestic tax issues is widely cited, as is his expert testimony on behalf of US and foreign taxpayers and the IRS/DOJ in many high-profile and precedent-setting tax disputes (including Du Pont, Xilinx, UPS, DHL, ACM, Bausch and Lomb, Dow [COLI], The Limited [NYS], Toys R Us [NYC], Cambridge Brands [Mass.], and the captive insurance cases).

He has designed, directed, and published research involving microeconomics, finance, industrial organisation, and econometrics. He has presented the results of these studies before several US Senate and House committees, the Federal Reserve Board, the Interstate Commerce Commission, the Federal Maritime Commission, the Federal Trade Commission, US claims, tax, and district courts, and numerous state legislative committees, courts, regulatory agencies, and arbitration panels. He has assisted in the writing of international tax legislation and regulations.

Irv holds a BS in economics from the Wharton School (University of Pennsylvania) and a PhD in mathematical economics from the Massachusetts Institute of Technology, where he taught computer science and finance. He has presented numerous papers in several fields of economics and regulation before various academic societies, professional organisations and industrial associations and has served as an editorial reviewer for the Journal of the American Statistical Association, the Journal of Industrial Economics, and the Journal of Risk and Insurance. His published papers, books, and monographs include Risk/Return: US Industry Pattern (Harvard Business Review), Rates of Return in the Property and Liability Insurance Industry: A Comparative Analysis (Journal of Risk and Insurance); The Consequences of Industrial Regulation on Profitability, Risk Taking, and Innovation; Torrens in the United States; and Economic Principles in Establishing Transfer Prices (Tax Management, Foreign Income Portfolio, co-author). His comments on current tax developments appear frequently in tax periodicals.


Keith Reams

Deloitte Tax LLP

980 9th Street Suite 1800
Sacramento, CA 95814-2738
US
Tel: +1 415 783 6088
Email: kreams@deloitte.com

Keith Reams is the US and global leader for clients and markets for Deloitte's global transfer pricing services practice. He has advised clients around the globe on intercompany pricing transactions with respect to income tax regulations in Argentina, Australia, Belgium, Brazil, Canada, Chile, China, Columbia, Czech Republic, Denmark, France, Germany, India, Ireland, Israel, Italy, Japan, Korea, Luxembourg, Malaysia, Mexico, the Netherlands, Norway, Peru, Poland, Singapore, South Africa, Spain, Switzerland, Taiwan, Thailand, the United Kingdom, and the United States.

Keith has assisted numerous multinational companies with international valuation and economic consulting services involving merger and acquisition activity, international tax planning, and restructuring and reorganisation of international operations. Keith is on the global tax management team for Deloitte's technology, media and telecommunications (TMT) group and is a leader in the area of transfer pricing for newly emerging industries, such as electronic commerce and cloud computing, where he has extensive experience around the world in helping clients extend their business models into new territories.

Keith has testified as a qualified expert in numerous valuation and transfer pricing disputes, including the cases of Nestle Holdings Inc. v. Commissioner; DHL Corp. v. Commissioner; and United Parcel Service of America, Inc. v. Commissioner. In addition, he is one of only three economists in the United States approved by the New York State Department of Taxation and Finance to provide transfer pricing expertise and testimony in cases involving cross-border transactions within commonly controlled affiliated groups. He has also helped many clients to successfully resolve valuation and transfer pricing disputes before they reach trial.

Keith completed course requirements for a PhD in international finance from New York University. He holds a master's of arts degree in economics from California State University Sacramento and a BS degree in chemical engineering from Stanford University.


William Schmalzl

Mayer Brown

71 S Wacker Drive
Chicago, IL 60606
US
Tel: +1 312 701 7225
Fax: +1 312 706 9202
Email: wschmalzl@mayerbrown.com
Website: www.mayerbrown.com

William Schmalzl focuses on tax litigation, corporate tax planning and state tax advice. He represents clients in all stages of tax litigation including audits, administrative proceedings, US Tax Court, federal district court and courts of appeals and Illinois state courts. The issues he has litigated include IRC section 482, the investment tax credit, research tax credit, sale-leasebacks, foreign tax credits, franchises, patents and other intangibles. William's undergraduate majors in economics and mathematics have proven invaluable in the preparation of expert reports and in the examination of expert witnesses at trial. William's trial experience includes Seagate Technology, National Semiconductor, United Parcels Service, RJR Nabisco, ConEd and Flextronics.

Before he joined Mayer Brown, William served as a clerk to the Honourable Robert Ainsworth, Jr, of the 5th Circuit Court of Appeals (1977-1978).

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition. "The firm's extensive experience spans the full gamut of controversy work, from administrative appeals to litigation in the trial court and at appellate court level".


Ronald Schrotenboer

Fenwick & West

Silicon Valley Center
801 California Street
Mountain View, CA 94041
US
Tel: +1 650 335 7207
Fax: +1 650 938 5200
Email: rschrotenboer@fenwick.com
Website: www.fenwick.com

Ronald Schrotenboer is a partner at Fenwick & West, practising in the area of taxation. Ronald practises out of the firm's Mountain View office in California.

His practice includes both domestic and international federal income tax as well as state income and sales tax. A significant part of his practice includes tax planning for pending transactions. He represents both US-based companies in domestic and international transactions, as well as foreign based companies with operations in the US. He also has been, and continues to be, involved with many Internal Revenue Service and state income tax audits, appeals and tax court cases, including §482 transfer pricing cases.

His published decisions include Xilinx, Inc. v. Commissioner, (stock option amounts not required to be cost shared under § 482); Sun Microsystems v. Commissioner (incentive stock option deduction qualifies for R&D credit); appeal of Finnigan Corporation, (throwback rule is applied on a unitary basis; appeal of Joyce overruled); petition of Intel Corporation, (technology transfers are not subject to California sales tax).

Ronald has written articles on various tax topics for the Journal of Taxation, Tax Notes, Taxes International, the Journal of State Taxation and other periodicals. He has spoken for many tax groups including the Alliance for Tax Legal and Accounting Seminars, The Council on International Tax Education and Tax Executive's Institute. He has also taught a graduate course at Golden Gate University on the taxation of high technology and a graduate course at San Jose State University on sales taxation.

Ronald received his BA degree with honours in 1977 from Calvin College in Grand Rapids, Michigan. He received his JD degree magna cum laude from the University of Michigan in 1980. He graduated as a member of the Order of the Coif and was an editor on the Michigan Law Review for two years.


Barry Shott

PwC

300 Madison Avenue
New York, NY 10017
US
Tel: +1 646 471 1288
Fax: +1 813 741 5278
Email: barry.shott@us.pwc.com
Website: pwc.com/taxcontroversy

Barry Shott is a senior managing director in PwC's tax controversy and regulatory services (TCRS) and advance pricing & mutual agreement (APMA) and transfer pricing controversies practices. In his role, he assists clients as they manage issues with the Internal Revenue Service (IRS) and other taxing authorities around the world. His work includes clients in the energy, entertainment, technology, mining, pharmaceutical industries and high wealth individuals.

Before joining PwC, Barry served as the deputy commissioner (international) for the IRS Large and Mid-Size Business (LMSB) division and he was the United States competent authority.

As the deputy commissioner, he provided Service-wide leadership and guidance on international matters, and promoted efficient and effective international tax administration by helping taxpayers operating internationally understand and meet their tax responsibilities. As the United States competent authority, he was responsible for implementing tax treaties and information exchange agreements, and engaging with foreign governments and taxpayers in resolving tax controversies in the MAP and APA processes.

He participated in various initiatives with the Organisation for Economic Co-operation and Development (OECD) and the Inter-America Centre for Tax Administration (CIAT).

Before his appointment as deputy commissioner, Barry served as the financial services industry director. In this role, he led a diverse industry of domestic and foreign banks, brokers, insurance companies, investment bankers, mutual funds, law and accounting firms, and other financial intermediaries.

Barry has more than 35 years of audit field experience, in government, in a wide variety of positions. Some of these roles include serving as industry director for the communications, technology and media industry in California, director of field operations for financial services in Manhattan, New York, and acting director of the National Research Programme in Washington, DC.

He was named a leading adviser in International Tax Review's 2014 Tax Controversy Leaders guide.

Barry is a certified public accountant (CPA) in New Jersey and New York, a member of the AICPA, serves on the AICPA's IRS Advocacy & Relations Committee and is a graduate of Rutgers, the State University of New Jersey.


George Soba

Deloitte Tax LLP

191 Peachtree St Ste 2000
Atlanta, GA 30303-1749
US
Tel: +1 404 220 1153
Email: gsoba@deloitte.com

George Soba is a principal of the Deloitte Tax LLP (Deloitte US) transfer pricing practice. George has more than 18 years of experience with Deloitte Tax representing US and foreign multinational clients in transfer pricing controversies (audits, appeals, and competent authority proceedings between the US and foreign tax authorities), and in advance pricing agreements (APAs). He advises clients on the transfer pricing aspects of global tax rationalisation, planning, documentation, and audit defence preparation. George's industry experience includes aerospace; consumer goods companies (retailers, distributors, and manufacturers); e-commerce; financial transaction processing and electronic trading exchanges; healthcare (vertically integrated pharmaceutical companies, biotech, and medical instruments) and contract research organisations; heavy manufacturing (construction equipment, printing, automotive companies, and automotive parts manufacturers); real estate investment trusts (REITs); and technology (wafer manufacturers, chip design and manufacturing, internet-related optical routers, servers, and infrastructure).

Before joining Deloitte, George worked as a field attorney for nine years in the IRS Office of Chief Counsel, served as an adviser to IRS examination teams conducting transfer pricing audits, advised appeals officers on the resolution of transfer pricing matters, served as one of the first IRS field attorneys on APAs, was on the IRS litigation team for the Perkin-Elmer transfer pricing trial before the United States Tax Court, and was seconded to the IRS APA programme where he served as a team leader during the establishment of the APA programme. He then worked for two years in the Office of Associate Chief Counsel (International) advising large-case examination teams on transfer pricing issues, evaluating transfer pricing controversies for potential litigation by the IRS, advising the US competent authority on transfer pricing, permanent establishment, and business profits issues, and as a team leader in the APA programme.

George is a frequent speaker on transfer pricing topics and has authored and co-authored papers on transfer pricing audits, blocked income, APAs, and other topics. He holds an LLM in tax from New York University School of Law, and is a member of the American and Washington, DC Bar associations.


Scott Stewart

Mayer Brown

71 S Wacker Drive
Chicago, IL 60606
US
Tel: +1 312 701 7821
Fax: +1 312 706 9203
Email: sstewart@mayerbrown.com
Website: www.mayerbrown.com

Scott Stewart's practice is focused exclusively on tax disputes and transfer pricing matters. He represents taxpayers at all levels of federal tax controversy, including audits, administrative appeals before the Internal Revenue Service, mediation involving the appeals division of the IRS, and litigation before the US Tax Court.

Recognised by Chambers USA each year from 2006 through 2015, Scott is described as "a talented litigator and corporate adviser" who wins the confidence of clients with his "extraordinary communication skills" and "broad and deep experience". He is "recommended for his spot on judgment and analysis," "his responsiveness and strategic thinking" and his "ability to anticipate issues before they arise." Chambers notes that he is "particularly adept at handling transfer pricing cases at all levels". Similarly, Euromoney recognises Scott in its 'Guide to the World's Leading Tax Advisers' and Legal 500 recognises his "wide range" of experience and cites his "very strong reputation" in tax controversy.

Scott has extensive experience with deductibility of interest expense in related-party transactions, including debt-versus-equity characterisation and sham transaction and economic substance issues, dating back to his involvement in the landmark Nestlé Holdings case during the 1990s. Recently, Scott led the Mayer Brown team that filed 15 Tax Court petitions concerning debt-equity issues on behalf of Tyco International and related companies. The cases involve $3 billion in interest expense incurred from 1998 through 2000.

Scott is also experienced in all aspects of international transfer pricing, including cross-border movements of tangible and intangible property, advance pricing agreements, cost sharing arrangements, section 6662 documentation, transfer pricing litigation, and issues related to section 936 Puerto Rico possessions corporations. His transfer pricing litigation experience includes a number of the major cases of the past two decades, such as National Semiconductor, Seagate Technology, Nestlé Holdings and United Parcel Service.

Scott's experience also includes acquisition-related issues, such as valuation of tangible and intangible assets. He advises clients on tax treaty matters, competent authority issues, attorney-client and related privilege issues, civil and criminal tax penalties, and accounting for tax matters under FIN 48 of the Financial Accounting Standards Board. His industry experience includes manufacturing, pharmaceutical, medical device and food processing companies. Scott holds a JD from Harvard Law School and an MBA from the Johnson Graduate School of Management at Cornell University.


David Swenson

PwC

600 13th Street NW, Suite 1000
Washington, DC 20005
US
Tel: +1 202 414 4650
Email: david.swenson@us.pwc.com
Website: pwc.com/taxcontroversy

David Swenson is the global leader of PwC's tax controversy and dispute resolution (TCDR) network and is resident in the Washington, DC office. The TCDR global network includes more than 650 tax controversy professionals, located in upwards of 80 countries across the globe, who assist multinational companies to prevent, manage, and resolve tax audits and disputes worldwide.

Following a prominent legal career spanning 25 years, David has substantial experience in advising multinational corporations (MNCs) on international tax matters, and assisting companies in their efforts to pursue a variety of measures aimed at proactively preventing, efficiently managing, and favourably resolving tax audits and disputes worldwide. Over the years, David has participated in more than 250 tax controversies involving audits and disputes between MNCs and the IRS, as well as dozens of other revenue authorities around the world.

Many of these tax disputes were resolved at the audit level or through the proactive use of administrative appeals, mediation, arbitration, APAs, or the competent authority/MAP process. Other controversies were docketed in a US court of law, proceeded to trial, and resulted in important decisions for MNCs, including cases involving transfer pricing (Bausch & Lomb I), the foreign tax credit (Ampex), competent authority matters (Yamaha), the definition of 'manufacturing' for Subpart F purposes (Bausch & Lomb II), foreign currency (Carborundum), and intellectual property rights (Exide/Exxon). David also participated in several landmark tax cases before the US Supreme Court, including the Barclays Bank, Boeing, and Goodyear cases. David has been described as "one of the top five tax controversy experts in the US," and he received recognition as a "leading attorney" in US tax litigation by Chambers US, and as one of the world's top 25 transfer pricing specialists.

In addition, David received a Meritorious Service Certificate from the Treasury Department and IRS, and has been an adjunct professor at Georgetown University Law Center, where he continuously taught courses for 25 years relating to international corporate income taxation. David received his MLT from Georgetown University Law School, and his JD, with honours, and BA, with distinction, from the University of Mississippi. David also has been admitted to practice before the US Tax Court, the US Court of Federal Claims, numerous US Federal Courts of Appeal, and the US Supreme Court.


Gary Wilcox

PwC

600 13th Street NW, Suite 1000
Washington, DC 20005
US
Tel: +1 202 312 7942
Fax: +1 678 529 4506
Email: gary.wilcox@us.pwc.com
Website: pwc.com/taxcontroversy

Gary Wilcox is a principal with PricewaterhouseCoopers in Washington, DC, where he co-leads a US controversy team that actively advises clients during the audit management and appeals and resolution phases of an IRS dispute. Gary also works closely with corporate and international specialists in cross-border transactions to help clients prepare for potential controversy. Gary's team frequently seeks rulings and other guidance for clients from IRS and Treasury as a means of proactively avoiding tax controversies.

Gary was recently a partner with Morgan Lewis, where he headed up the firm's tax practice. Before that, he served as deputy chief counsel (technical) in the Office of Chief Counsel of the Internal Revenue Service and, earlier, as a leader of PwC's mergers and acquisitions practice.

Gary was litigation counsel to Iberdrola and ScottishPower in NAGP v. Commissioner, a 2012 US Tax Court decision that upheld nearly $1 billion of taxpayer's interest deductions on cross-border intercompany debt.

A frequent lecturer on corporate tax issues, Gary is an author of the BNA TaxManagement Portfolio entitled Corporate Acquisitions- (A), (B), and (C) Reorganisations.

Gary has an LLM in taxation from New York University, a JD with highest honours from the University of Oklahoma and an undergraduate degree (cum laude) from Texas Tech University.


Joel Williamson

Mayer Brown

71 S Wacker Drive
Chicago, IL 60606
US
Tel: +1 312 701 7229
Fax: +1 312 706 9204
Email: jwilliamson@mayerbrown.com
Website: www.mayerbrown.com

Joel Williamson is widely acknowledged as one of the nation's leading tax attorneys and litigators. He has litigated more than 60 tax cases. His experience includes the trial of six major IRC § 482 transfer pricing cases, including Eli Lilly, GD Searle, Westreco (Nestlé), Seagate Technology, National Semiconductor, and United Parcel Service. Presently, Joel is serving as trial counsel in Guidant LLC and Eaton, two cases involving IRC § 482 issues. Joel has also litigated numerous cases involving economic substance, including the United Parcel Service case just noted, as well as the Flextronics, ConEd and Tribune.

In the international tax area, Joel has litigated subpart F, constructive triangular dividend and R&D moratorium issues, Gulf Oil, The Limited, and Boeing, and Brazilian and other foreign tax credits for banks, Bankers Trust and Riggs Bank, as well as foreign versus domestic-source income IRC § 863(b) questions, Intel. In addition, Joel has litigated IRC § 338 corporate acquisition related issues, like debt versus equity involving Nestlé's acquisition of Carnation. Joel is presently serving as trial counsel in the mega Tyco debt versus equity cases.

Joel has litigated significant procedural questions, including the proper role of IRS trial counsel in the audit examination process, Westreco (Nestlé). He is also experienced in summons enforcement actions for both foreign and domestic records.

Joel is proud to have been recognised by Chambers USA as a 'leading lawyer' in each of the years 2003 to 2015. In addition, Legal 500 recognised him as a 'leading lawyer' in 2008, 2011, 2012, 2013, 2014 and 2015, describing Joel as a "highly skilled trial attorney possessing great judgment".

Mayer Brown was recently named Tax Controversy Team of the Year in the Legal 500 US Awards 2014. "Mayer Brown is 'among the best' and fields a large team...dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the 2014 US edition.

Joel served as an officer in the United States Army from 1970 through 1972, assigned to the Offices of the Staff Judge Advocate, 12th Support Brigade, Ft. Bragg, NC, and subsequently to Saigon Support Command, the Republic of South Vietnam. After his return from Vietnam in 1972, Joel joined the Chief Counsel's Office, US Department of Treasury. In 1978, he was appointed one of 20 special trial attorneys located throughout the US. Joel joined Mayer Brown in 1986 as a partner


Todd Wolosoff

Deloitte Tax LLP

1633 Broadway
New York, NY 10019-6754
US
Tel: +1 212 492 4890
Email: twolosoff@deloitte.com

Todd Wolosoff is the Deloitte global and US leader for transfer pricing, and the Deloitte Tax transfer pricing managing partner. He is based in the New York office. He has nearly 30 years of experience as a partner in representing multinational corporations in transfer pricing and international tax matters.

Todd was promoted to his current roles in 2012 and 2011 respectively. Previously, Todd was the partner-in-charge of transfer pricing for the northeast United States and the leader of the tri-state transfer pricing group since its inception in 1990. He is a founding member of the Deloitte Tax national transfer pricing leadership group.

In Todd's global leadership role, he is responsible for creating and implementing strategy and providing vision and leadership to the Deloitte member firm network's nearly 2,000 transfer pricing professionals worldwide. In his US transfer pricing leadership role, Todd is responsible for all aspects of the US transfer pricing group including strategy, operations, hiring and human resources. Todd has approximately 50 partners, principals and directors and hundreds of professionals as part of his team.

Todd serves as an adviser to several of the world's largest multinationals and has conducted numerous transfer pricing planning studies in virtually all industries, with a particular focus on pharmaceuticals, electronics, financial services, consumer products, automotive, TMT, and fashion and beauty products, for both inbound and outbound taxpayers.

He has been recognised by Euromoney as one of the world's leading transfer pricing advisers and was one of four Deloitte Tax partners selected by Mondaq in its survey of the top attorneys in the United States. Todd is also recognised by International Tax Review as one of the world's leading tax advisers.

Todd holds a BS in economics from the Wharton School, the University of Pennsylvania, a JD from St. John's School of Law, and an LLM from New York University School of Law. Todd is a licensed attorney and a CPA, as well as a member of the American Bar Association, the New York State Bar Association, the American Institute of Certified Public Accountants, and the New York Society of Certified Public Accountants.


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