Directory of contributors

Suite 500

555 12th Street, NW

Washington, DC  20004-1207

Tel: +1 202 879 5307

Fax: +1 202 638 7313

Email: dclark@deloitte.com

Richard Clark is a principal in the Washington, DC, office, serving as co-director of the US Transfer Pricing Team. Richard has over 25 years experience as a consulting economist, including 15 years in transfer pricing. Currently, he assists multinationals in developing intercompany pricing strategies for tax planning and providing economic expertise in APAs, tax audits and competent authority proceedings involving tangible and intangible property transfers and services. He has experience working with major foreign and US multinationals in many industries, including the automotive, semiconductors, medical equipment and telecommunications sectors.

Richard served as editor-in-chief and columnist for the Journal of Global Transfer Pricing and has published articles on transfer pricing in the journal and other tax publications. He has been a frequent speaker on transfer pricing issues and has served as a guest lecturer at IRS internal transfer-pricing trainings. He also has been recognized in Euromoney's Guide to the World's Leading Transfer Pricing Advisers.

Richard obtained his MS and PhD (Managerial Economics) from Cornell University, his MPA from the University of Colorado and a BA from Cornell University.

Suite 600

225 W Santa Clara Street

San Jose, California 95113-2303

Tel: +1 408 704 4418

Fax: +1 408 704 8417

Email: memmer@deloitte.com

Maurice Emmer is a partner in the international tax practice. He is a member of the Washington National Office and is based in the firm's San Jose, California, office. Maurice is the leader of the firm's Global Earnings Mobility Strategies (GEMS) practice.

For 23 years prior to joining Deloitte & Touche, Maurice practised law in Baker & McKenzie's international tax group, where he represented both domestic and foreign-based multinational organizations in tax matters, including substantial tax controversies.

In recent years Maurice has been selected by the International Tax Review as one of the most prominent tax advisers in the Western United States. He is featured in Guide to the World's Leading Tax Advisers, appears in Strathmore's Who's Who in the US and has been selected as a life member of the national registry of Who's Who published in the 1999 edition. Maurice also was selected by Euromoney for its 2000 Guide to the World's Leading Transfer Pricing Advisers.

Maurice is a 1978 graduate of the University of Chicago Law School and a 1969 graduate (BS degree in Accounting) of the Wharton School of Finance and Commerce of the University of Pennsylvania. He is a member of the Bars of California, Illinois and New York, and of the American Institute of Certified Public Accountants.

185, avenue Charles de Gaulle

Neuilly, France

Tel: +33 1 55 61 48 12

Fax: +33 1 40 88 28 28

Email: wfinan@deloitte.fr

William Finan is a partner working from the firm's Paris office. As an economist who has specialized in transfer-pricing matters for over 15 years, Bill has gained wide recognition as one of the foremost transfer-pricing economists globally. Bill's clients have included major companies in the computer, pharmaceuticals, semiconductor, software, motor vehicles and other industries. He has published extensively on transfer-pricing matters in such publications as Journal of Transfer Pricing, Journal of Global Transfer Pricing, Journal of Technology Transfer, and International Taxation.

Bill obtained his MBA in Corporate Finance and his PhD in Economics from the Wharton School of Finance and Commerce (University of Pennsylvania) and his BS in Industrial Engineering from Cornell University.

MS Shibaura Building

13-23, Minato-ku, Tokyo 108-8530, Japan

Shibaura 4-chome

Tel: +81 3 6213-3976

Fax: +81 3 6212-3801

Email: sfukushima@deloitte.com

Setsuko Fukushima is a partner in the Tokyo-based Transfer-Pricing Team. Prior to joining Deloitte Touche Tohmatsu, she was a tax specialist at KPMG's New York office, and then a partner in the Global Transfer Pricing Services group at KPMG's Tokyo firm.

Setsuko has been selected for inclusion in Euromoney's 2001 Guide to the World's Leading Transfer Pricing Advisers. Her specialities include APAs and competent authority procedures for transfer pricing audit cases. She has served as an adviser in US-Japan APA cases, representing a client before the Japanese tax authority, and extended her experience to include other countries, such as Australia and Germany.

Setsuko has also worked on several global restructuring projects for Japanese multinational companies.

Setsuko has published several articles in BNA's Transfer Pricing Report (US), Kokusai Zeimu (Japan), Zeimu Kouhou (Japan), and International Tax Review (UK), and has conducted presentations on transfer pricing and other areas of taxation for major organizations.

Setsuko has a Master of Science in taxation from the State University of New York at Albany and a BA in economics from International Christian University in Tokyo. She is also a US-certified public accountant and is fluent in English.

555 12th Street, NW

Suite 500

Washington, DC  20004-1207

Tel: +1 202 378 5224

Fax: +1 202 661 1963

Email: jgannon@deloitte.com

Jim Gannon is a partner in the Washington, DC, office and a member of the Washington International Tax Services Group. Prior to joining the firm, Jim was a partner in the Arthur Andersen Office of Federal Tax Services. Jim has over 15 years of experience in international tax and advises clients on cross-border mergers, acquisitions and restructurings; effective tax rate minimization through foreign tax credit planning; subpart F and anti-deferral planning; allocation and apportionment of deductions; cross-border E-commerce; and structuring the intellectual property ownership of multinationals.

Jim is a frequent speaker on international tax issues and has appeared before the Tax Executives Institute and the Georgetown University Law School Conference. He has been published in CCH's CYBERTAXATION treatise, the Tax Management International Journal, and is a co-author of the Tax Management portfolio, Allocation and Apportionment of Expenses-Regs. §1.861-8. He was also a contributor to International Tax Review's publication, Intellectual Property (2002).

Jim obtained a master's in public accounting from the University of Texas (Austin) and a Bachelor of Science in Accountancy from the University of Illinois (Urbana). He is a member of the AICPA and the Illinois Society of CPAs.

Suite 1400, BCE Place

181 Bay Street

Toronto, ON M5J 2V1

Canada

Tel: +1 416 601 6026

Fax: +1 416 601 6480

Email: rigarland@deloitte.ca

Richard Garland is a partner with the national transfer pricing and competent authority group and is based in Toronto, Canada. He has over 15 years of public accounting experience focused in the area of corporate international taxation.

Richard has assisted clients in all aspects of international taxation, with particular emphasis on tax treaty issues, cross-border financing structures and transfer pricing. Over the past several years, Richard's work has been focused on transfer pricing.

Richard has assisted clients in various industries with all aspects of transfer pricing, including planning studies, documentation studies, controversy, competent authority matters and APAs. Richard has extensive experience assisting clients in dealing with complex transfer-pricing issues related to intangibles and R&D. He is a member of the firm's technology, media and telecommunications tax practice and works closely with the firm's international tax specialists in developing and implementing tax-efficient strategies for ownership of intellectual property.

Richard has presented frequently on various international tax and transfer-pricing issues. Richard graduated from the University of Waterloo with a BMath and is a Chartered Accountant.

Suite 500

555 12th Street, NW

Washington, DC  20004-1207

Tel: +1 202 378 5222

Fax: +1 202 661 1960

Email: ggodshaw@deloitte.com

Gerald Godshaw is a principal in the National Tax Office in Washington, DC where he is a member of the Transfer Pricing Group. From 1990 to 2002, he was a participating principal in Arthur Andersen's Office of Federal Tax Services in Washington, DC. His areas of specialization include transfer pricing, corporate taxation, state and local taxation, and policy analysis.

Gerald has spent 12 years conducting a number of transfer-pricing studies focusing on the transfer of goods, intangibles and services. The work has spanned a variety of industries, including the pharmaceutical, biotechnology, medical devices, computer software, semiconductors and automotive sectors. Much of his concentration has been in the pharmaceutical and related healthcare industry, resulting in one of the first APAs for a major non-US-based pharmaceutical company, a global planning study of intangibles for a US-based pharmaceutical company, including cost sharing, and intangibles shifts and a global documentation study for several pharmaceutical, biotech and medical device companies (both US and non-US based companies).

Gerald received his PhD in economics from Syracuse University, his undergraduate degree from St. Lawrence University, and spent one year at the University of Vienna, Austria.

180 The Strand

London

WC2R 1BL

United Kingdom

Tel: +44 0 207 859 4204

Fax: +44 0 207 304 1919

Email: rhaigh@deloitte.co.uk

Ron Haigh is a partner in the London office's Multinational Corporations Tax Group. He is also UK national director of the Deloitte & Touche international competent authority practice. Ron is featured in Euromoney's 2001 Guide to the World's Leading Transfer Pricing Advisers and is a frequent speaker and published author on international tax matters.

Prior to joining Deloitte & Touche in April 2001, Ron was deputy director of the Inland Revenue's International Division. In this position Ron was the UK's competent authority for purposes of its double taxation conventions in the transfer pricing area and played a prominent role in the renegotiation of the UK-US double tax treaty. In addition, from 1993 until early 2001 he chaired the OECD's Working Party and its Steering Group on the Taxation of Multinational Enterprises, which were responsible for the publication of the 1995 document Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

Ron now represents both UK and foreign-based major multinational clients in planning transactions with international implications, advising in particular on APAs, building and conducting defence strategies, including ensuring adequate transfer-pricing documentation, handling government contact (including contact with competent authorities), and lobbying for change.

Adriaan Volkerhuis

Oostmaaslaan 71

3063 AN Rotterdam

Tel: +31 10 880 15 42

Fax: +31 10 880 16 72

Email: theijenrath@deloitte.nl

Thijs Heijenrath is a partner in the firm's Rotterdam office, serving as the managing partner of the Dutch Transfer Pricing Group and a member of the International Transfer Pricing Task Force. Thijs joined the firm in 1995 and was previously an inspector of taxes in the ruling team of the Dutch tax authorities. He is currently responsible for all transfer pricing engagements of the Dutch firm, including planning studies, audit defences, negotiating APAs and advance tax rulings (ATRs), mutual agreement procedures and documentation projects. He is frequently involved in pan-European re-engineering projects and in negotiating unilateral and bilateral APAs and ATRs for multinationals in the chemical, consumer products, engineering, high tech, IT, pharmaceuticals and tobacco industries.

Thijs regularly speaks and writes on transfer pricing issues. He holds a master's in tax law from the University of Tilburg. He is a lecturer at the LLM program of the European Tax College at the University of Tilburg and Leuven, as well as at the International Master Program of the International School of Economics in Rotterdam. Thijs is a certified tax advisor and a member of the Tax Advisors Association, which he represents before the Ministry of Finance on transfer pricing issues.

180 Strand

London WC2R 1BL

United Kingdom

Tel: +44 20 7859 4226

Fax: +44 20 7304 1918

Email: jhenshall@deloitte.co.uk

John is a partner in the firm's London International Tax Practice, and is the leader of the Global Earnings Mobility Strategies (GEMS) practice in Europe. In this role, John is responsible for service to clients on all aspects of cross-border planning, pricing and implementation services.

John has recently assisted companies in the electronics, financial, retail, biotechnology, defence, medical and general trading industries in the development and/or defence of their tax-optimized business structures. He draws on his experiences as an inspector of taxes both to reduce the risk of aggressive audits and to optimize the negotiating position with inspectors, the International Division and Special Compliance Office of the Inland Revenue.

John has also served as a consultant to foreign governments (the People's Republic of China and the Islamic Republic of Iran) concerning the modernization of their approach to international taxation.

Training initially with the UK Inland Revenue, John spent 12 years with PricewaterhouseCoopers prior to joining Deloitte in 2000. John has been involved with transfer pricing planning and defence on a full-time basis for five years. His articles are regularly published in tax journals, including International Tax Review, Euromoney and International Transfer Pricing Journal, and he is the co-author of International Transfer Pricing 1999-2000, published by CCH.

200 East Randolph St,

76th floor

Chicago IL, 60601

Tel: +1 312 242 9336

Fax: +1 202 242 8336

Email: khielscher@deloitte.com

Kai C. T. Hielscher is in charge of Deloitte & Touche LLP's US central region transfer pricing team, which serves clients in over 20 states out of the Chicago, Dallas and Minneapolis offices. Previously, he served in a managing function for the firm's transfer pricing team in Japan, where he was selected for inclusion in Euromoney's World's Leading Transfer Pricing Advisers in 2001. He is listed as one of the world's leading tax advisers for the US in the 2002 Euromoney survey.

Building on his tricultural background, Kai has worked as project leader on complex transfer pricing and IP transfer projects for North American and foreign multinationals. Examples of his recent projects include designing and negotiating APAs for life sciences industry transactions involving billions of dollars with the IRS, Japanese and European tax authorities and implementing tax-efficient residual profit split and valuation methods-based IP migration mechanisms with APA coverage for electronics companies; and

Kai designed and negotiated the first three pharmaceutical APAs for the US IRS and the Japanese NTA that were not the result of an assessment case in competent authorities, and is currently negotiating another bilateral APA involving the Irish tax authorities.

181 avenue Charles de Gaulle

92524 Neuilly sur Seine Cedex, France

Tel: +33 14 0 88 70 21

Fax: +33 1 40.88.86.91

Email: dlamoureux@deloitte.fr

Denis Lamoureux is supervisor working with Deloitte & Touche's Transfer-Pricing Group in Paris. He has recently worked on APAs, competent authority procedures, global and French transfer pricing documentation and tax defence before the French tax authorities.

Denis graduated from the Ecole des Hautes Etudes Commerciales (HEC) and received a DESS (one year after master's degree) in International Tax at Law School Paris II - Assas.

Suite 2300

411 E Wisconsin Avenue

Milwaukee, WI 53202-4496

Tel: +1 414 347 6110

Fax: +1 414 905 0509

Email: dlange@deloitte.com

Dan Lange, based in the firm's Milwaukee, Wisconsin, office, is the managing partner of the US international tax service group. Dan has worked with a number of Fortune 500 companies on a wide variety of international tax issues, including international expansion, cross-border corporate acquisitions and restructurings, earnings repatriation, cross-border financing, foreign tax credit planning and foreign country tax reduction.

Dan has travelled throughout the US making presentations to tax executives on various international planning strategies of multinational taxpayers. He has authored international tax articles in several tax publications, including Tax Management International Journal, TAXES and State Tax Journal. Dan is also a co-author of the BNA portfolio covering the allocation of US expenses and foreign earnings and profits.

Dan graduated from the University of Wisconsin with a master's in tax and an undergraduate degree in accounting.

Suite 600

225 W Santa Clara Street

San Jose, California 95113-2303

Tel: +1 408 704 4770

Fax: +1 408 704 8770

Email: lmcdermott@deloitte.com

Leslie McDermott is a senior manager in the San Jose, California, office and a member of the GEMs Group. Leslie has worked exclusively in the international tax area for the past nine years and has extensive experience in structuring both US inbound and outbound investments. She has managed the implementation of global restructurings, mergers, acquisitions and dispositions for several large non-US and US-based multinationals. As a member of the GEMs Group, Leslie specializes in the planning and implementation of global earnings mobilization and effective tax-rate reduction for large multinationals.

Leslie received her JD from Fordham Law School and her LLM in taxation from New York University School of Law. She is proficient in Japanese and has co-authored several articles covering such topics as worldwide tax minimization for multinationals, entity classification elections and transfer pricing.

181 avenue Charles de Gaulle

92524 Neuilly sur Seine Cedex, France

Tel: +33 1 55 61 63 46

Fax: +33 1 40 88 86 91

Email: Gmonsellato@deloitte.fr

Gianmarco Monsellato is an international tax partner in Paris in charge of the French transfer-pricing service line. He advises leading multinationals on strategic planning and international tax defence. Gianmarco, who has been involved in transfer-pricing issues in France since 1994, is considered the most experienced French advisor under the new transfer-pricing approach initiated by the US.

Gianmarco's recent assignments include the formulation of global transfer-pricing policy, including mobile income strategies, for listed companies; the negotiation of APAs; participation in competent authority proceedings; tax planning for intangibles; and the creation of global transfer-pricing methodology for global trading activities.

Gianmarco is a tax law professor at the Ecole des Hautes Etudes Commerciales (HEC), and a guest lecturer at te University of Paris II and the University of Bologna. He has co-authored two books on transfer-pricing and has published numerous articles. He has been selected both as a leading tax adviser and a leading transfer-pricing adviser in France by Euromoney.

Gianmarco graduated from HEC and is an attorney at the Hauts de Seine Bar.

Bahnstraße 16

40212 Düsseldorf

Germany

Tel: +49 0 211 8772 475

Fax: +49 0 211 8772 260

Email: acroeder@deloitte.de

Achim Roeder is a director in the Düsseldorf office, serving in the German Transfer Pricing Group. Achim has more than seven years of experience in German and international taxation. Prior to joining the firm, he spent four years working in the German financial services industry. His experience is supplemented by extensive research projects in accounting and auditing issues, as well as in corporate finance and in the financial services industry. His financial services project experience includes tax planning for derivatives trading transfer pricing for a European bank, tax planning for US investment banking and a cost cutting project for the securities settlement/clearing department of a German bank.

Achim obtained his diploma in Business Economics, his Master of Arts, and his PhD in business taxation from the University of Bochum. He published a volume on the economics of anti-avoidance legislation in international German tax law, and has worked on a number of publications covering a broad range of business and economic topics.

Admiraliteitskade 50

3063 ED

Rotterdam, Netherlands

Tel: +1 202 879 4938

Fax: +1 202 638 7313

Email: ashapiro@deloitte.com

Alan Shapiro works with the firm's largest non-US and US multinational companies to develop and implement transfer-pricing strategies. He has over 20 years of experience, of which the last 10 have been devoted to specializing in the full range of transfer-pricing issues. Alan is one of the firm's leading experts on the cross-border taxation of intangible property, including the development of transfer-pricing regimes that focus on minimizing the worldwide tax imposed on intangible property. He has represented clients in controversies with the IRS and in competent authority proceedings between the US and foreign tax authorities. He is a member of the bar of the State of Pennsylvania and a certified public accountant.

Alan is widely quoted on international tax topics in BNA's Daily Tax Report and transfer-pricing report. He has authored or co-authored numerous articles on transfer pricing in IBFD's International Transfer Pricing Journal, BNA's Transfer Pricing Report and Tax Notes International.

Alan received his JD and an LLM in Taxation from Georgetown University.

180 The Strand

London

WC2R 1BL

Tel: +44 0 207 859 4543

Fax: +44 0 207 859 4289

Email: rvitou@deloitte.co.uk

Richard Vitou is responsible for the global coordination of indirect-tax services to a number of the Firm's multinational clients. He has been involved in advising on the indirect-tax issues arising from a wide range of income mobility projects, from commissionaire structures to cost-sharing arrangements and procurement centers.

Richard is a member of the Association of Taxation Technicians (ATT) and an associate of the Chartered Institute of Taxation of England & Wales (ATII/CTA).

Oostmaaslaan 71

3063 AN

Rotterdam, Netherlands

Tel: +31 10 880 1278

Fax: +31 10 880 1880

Email: awijnen@deloitte.nl

Alex Wijnen is a partner with the firm's GEMS group and serves as the reporting/IT expert for large supply chain projects. In this capacity, he concentrates on operational changes from a reporting and IT perspective, taking into account a company's business model, the accounting conversion of VAT and Intrastat requirements and the management information, (US) GAAP reporting and local statutory reporting requirements. He comes to Deloitte & Touche from Andersen, where he worked with multinationals throughout Europe and the US. Alex is currently based in Amsterdam, and was previously based in Australia.

Alex's experience in GEMS and tax supply-chain consulting focused on the development of a specialist international integrated reporting and systems practice with the mission of designing and implementing large-scale, pan-regional, supply-chain structures. He is a pioneer in his area of specialization and one of very few in the world designing integrated supply-chain IT reporting configurations in ERP and other legacy systems environments (middleware solutions).

Alex is a Dutch registered accountant (NIVRA) as well as an Australian chartered accountant (ICAA). He is a graduate from the higher business school in the Hague.

Orlyplein 10

1043 DP Amsterdam

Netherlands

Tel: +31 20 582 4291

Fax: +31 20 582 4020

Email: pwilleme@deloitte.nl

In addition to his client responsibilities, Peter is head of the International Tax Practice of Deloitte Tax in Europe. Prior to joining Deloitte in 2002, he had over 19 years' experience in international tax with Andersen.

In 1996, 1999, 2000 and 2001, Peter was ranked as one of the best tax advisers in the Netherlands by International Tax Review. He specializes in international tax issues such as dual residents, hybrids and joint ventures. He serves primarily large multinational clients in the technology and communication industry.

Peter has published several articles on taxation in the technology and telecommunication industry in one of the leading Dutch computer magazines. He lectures widely on such topics as commissionaires and tax residence issues.

Peter has a masters degree in tax law from the University of Amsterdam.

Admiraliteitskade 50

3063 ED

Rotterdam, Netherlands

Tel: +31 10 880 14 92

Fax: +31 10 880 17 18

Email: klwinters@deloitte.nl

Klaas Winters has been a partner with Deloitte's international trade and customs group since 1999. In that capacity, he has served a variety of clients in all aspects of customs and trade matters, including anti-dumping levies, classification, origin, quota systems, refunds, appeals and administrative customs systems, including excise warehouses. He has more than 14 years of experience with Dutch customs.

Klaas has worked as a tax adviser on customs and international trade issues since 1992. Prior to joining Deloitte, he served as a technical specialist at a customs district for more than seven years, on matters concerning the harmonized system, questions regarding origin, quota systems, administrative and computerized systems and excise warehouses.

Klaas was the leading manager in a study for the European Commission concerning various aspects of the agreements regarding origin between the European Union, EFTA countries and Eastern European countries.

Klaas has served as a faculty member on training courses for Dutch and foreign customs officers, for a major Dutch transport service organization (EVO) and for a Dutch branch organization for exporting companies (FENEDEX). He has several publications to his name, and has served as visiting lecturer at the University of Leiden.

Suite 500

555 12th Street, NW

Washington, DC  20004-1207

Tel: +1 202 879 5645

Fax: +1 202 661 1023

Email: swrappe@deloitte.com

Steven Wrappe is a partner in the Washington, DC, serving as the director of national office's APA services. Prior to joining the firm, Steven was the most experienced of the IRS APA program's attorneys. In addition to his position with the APA program, Steven served as special assistant to the IRS national director of appeals and practised tax law with a Washington, DC, firm. Steve has more than 22 years of tax experience, including 12 years of specialization in transfer pricing and APAs.

Steven is an internationally recognized expert on transfer-pricing and dispute resolution, with over 100 speeches to groups including The International Fiscal Association, The Tax Executives Institute, The American Bar Association and The Federal Bar Association. He has published over 60 articles and chapters on transfer pricing topics in professional journals, and recently co-authored Transfer Pricing Rules, Compliance, and Controversy (CCH 2001). Steven has been selected for inclusion in the most recent Guide to the World's Leading Transfer Pricing Advisers, published by Euromoney's International Tax Review.

Steven obtained his LLM (taxation) from New York University School of Law and his JD from the University of Texas School of Law. He has a BBA in accounting from the University of Notre Dame and is a member of the State Bar of Texas and a certified public accountant.