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David F AbbottMayer Brown 1221 Avenue of the Americas New York, NY 10020-1001 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 vs. 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. 
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J Bradford AnwyllPwC 600 13th Street NW, Suite 1000 Washington, DC 20005 US Tel: +1 202 414 4326 Email: brad.anwyll@us.pwc.com Website: www.pwc.com/taxcontroversy J Bradford Anwyll is a principal in the transfer pricing group of PwC'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 more than 250 cases before the Internal Revenue Service's Advance Pricing and 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 guide since 2013, by Chambers USA for national tax litigation in 2008, by the Legal 500 for tax controversy in 2007, and Washington, DC Super Lawyers guide 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 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, 2nd 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. Following law school, Brad was a judicial clerk to the Honourable Marion T Bennett of the US Court of Appeals for the Federal Circuit. 
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Howard BermanDeloitte Tax LLP 30 Rockefeller Plaza New York, NY 10112-0015 US Tel: +1 212 436 2242 Email: hberman@deloitte.com Website: www.deloitte.com Howard Berman, Deloitte US, is a member of the tax controversy services team. Howard specialises in representing clients before the International Revenue Service (IRS) and in coordinating complex IRS examinations and appeals for multinational enterprises. 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 US 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. 
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Kevin BrownPwC 600 13th Street, NW Suite 1000 Washington, DC 20005-3333 US Tel: +1 202 346 5051 Email: kevin.brown@us.pwc.com Website: www.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 Internal Revenue Service (IRS) and chief operating officer 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 US 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.
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C Cabell ChinnisMayer 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 2067 Email: cchinnis@mayerbrown.com Website: www.mayerbrown.com Cabell Chinnis specialises in audits and appeals, focusing in the contentious area of transfer pricing. He has obtained speedy and favourable results by identifying key issues in each 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 Internal Revenue Service (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 matters within the IRS to senior agency personnel to facilitate resolution of audit issues. In appeals, Cabell specialises in handling complex matters and expediting the 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&D 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.
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Kerwin ChungDeloitte Tax LLP 555 12th St. 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, Deloitte US, is a principal in the Deloitte Tax 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 an Internal Revenue Service (IRS) transfer pricing adjustment and penalty assessment, amounting to more than $100 million. Kerwin has also been involved in a bilateral APA, covering cost sharing platform contribution transactions and 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 co-authored numerous publications, including 'Seeking efficiencies in the new IRS APA and MAP programmes', published by International Tax Review (November 2011); 'Competently Negotiating the US Competent Authority Process', published by the 59 Tax Executive No. 3, (May/June 2007); and the 'Transfer Pricing Rules and Compliance Handbook', published by CCH (2006). Kerwin has been included in Euromoney's Transfer Pricing Expert Guide since 2002 and in International Tax Review's Tax Controversy Leaders guide since 2015. 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.
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Kenneth B ClarkFenwick & West Silicon Valley Centre 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7215 Fax: +1 650 938 5200 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. The firm 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 Kenneth's practice is complex federal tax litigation and tax controversy work, with a significant emphasis on transfer pricing and international issues. He regularly practices in the US Tax Court and has appeared in many federal and state courts. He is widely published in the field of tax controversies. Kenneth has worked on numerous high profile tax controversy matters for clients such as Xilinx Inc., The Limited, Inc., Limited Brands Inc., Textron Inc., Apple Inc., Daimler AG, GM Trading, Dover Corporation, Adaptec, Inc., Analog Devices, Office Depot, and CBS. With four decades of experience, Kenneth also has 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) also have 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. Kenneth received a BA from the University of Redlands (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. Kenneth also received an MBA from the University of California at Berkeley 
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Ward ConnollyPwC 488 Almaden Boulevard San Jose, CA 95110 US Tel: +1 408 817 8234 Email: ward.connolly@pwc.com Website: www.pwc.com/taxcontroversy Ward Connolly is a principal in PwC's national tax services (NTS) group and is resident in the firm's Silicon Valley Technology Center of Excellence in San Jose, California. Ward is a member of PwC's advance pricing, mutual agreement and transfer pricing controversy practice. Ward has 20 years of experience as a tax professional and has represented US and foreign multinational enterprises in complex tax audits, administrative disputes (IRS Appeals), alternative dispute resolution (e.g. mediation), 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 guide 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. Prior to 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 School of Law, 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 written many technical articles for trade journals and other publications. Ward has been a frequent speaker for professional tax groups, including numerous chapters of the Tax Executives Institute and BNA/CITE.
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Daniel CookDeloitte Tax LLP Chicago, Illinois US Tel: +1 312 486 5478 Fax: +1 866 603 7464 Email: dancook@deloitte.com Website: www.deloitte.com Daniel Cook, Deloitte US, is a managing director specialising in federal tax controversy services. Dan has represented taxpayers at all stages of federal tax controversy, including IRS examinations, the IRS administrative appeals process, alternative dispute resolution proceedings, and collection due process matters. In addition, he has advised clients regarding pre-examination matters including audit readiness studies, internal company compliance initiatives, strategic planning initiatives and proactive voluntary disclosure initiatives by taxpayers to the IRS. Prior to joining Deloitte Tax, Dan also represented taxpayers in litigation proceedings before the US Tax Court, the US District Court, the US Federal Court of Claims and in post-trial appeals to the US Circuit Courts of Appeals. Dan's clients have included multinational enterprises in the finance, insurance, oil and gas, and pharmaceutical industries, as well as professional partnerships and their members, and individuals. Dan received a BA in 2000 from Carleton College; a JD, with distinction, in 2004 from the University of Iowa College of Law; and a LLM in taxation, with honours, in 2005 from the Northwestern University School of Law.
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Anthony CurtisPwC 300 Madison AvenueNew York, NY 10017 US Tel: +1 646 471 0700 Fax: +1 813 329 2215 Email: anthony.curtis@us.pwc.com Website: www.pwc.com/taxcontroversy A principal since 2000, Anthony Curtis is a senior economist, transfer pricing specialist and leader of the New York metro tax controversy practice, integrating tax controversy resolution and prevention specialists from federal and international tax, transfer pricing, state and local tax with former government and other specialists. Tony has 26 years of experience conducting economic analysis for PwC. For 24 years, he has specialised primarily in the economics of intercompany pricing, including planning studies to help taxpayers determine appropriate transfer prices for future transactions, economic studies for use in the defence of transfer prices under examination, and economic analysis for APA and Competent Authority negotiations with the IRS and foreign tax authorities. He currently is negotiating several APAs, transfer pricing audits, and Competent Authority cases with the Internal Revenue Service for his clients, including bilateral and multilateral cases involving China, Switzerland, and the UK. Tony is also the US retail and consumer products sector leader for the transfer pricing practice. As a result of this role, Tony works with PwC's leading retail, luxury goods, and consumer products clients to ensure that they have access to the best practices and personnel of the PwC network. He previously was the leader of the NY transfer pricing region, the practice's globally coordinated documentation service offering, as well as the Americas editor for PwC's transfer pricing news articles. He is also a frequent author and presenter. Tony is also passionate about PwC's people and enjoys recruiting and working on PwC's diversity and inclusion initiatives. Tony previously taught graduate courses in business economics and money and banking at Johns Hopkins University. He has a MBA with a concentration in marketing and a BBA with a concentration in business economics and public policy from The George Washington University and has completed several graduate classes in taxation at Fordham University.
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Paul DiSangroMayer Brown Two Palo Alto Square, Suite 300 3000 El Camino Real Palo Alto, CA 94306-2112 US Tel: +1 650 331 2045 Fax: +1 650 331 4545 Email: pdisangro@mayerbrown.com Website: www.mayerbrown.com Paul DiSangro focuses his practice on resolving tax disputes with the IRS and state agencies. Paul obtains favourable results in an efficient time frame by collaborating with clients to develop a clear strategy for navigating the thorny issues that arise in complex tax cases. He has more than 20 years' experience, representing clients in all facets of tax controversy, including audits and administrative appeals, alternative dispute resolution, and litigation. Paul has successfully handled a broad range of tax issues with the IRS, including, most recently, transfer pricing, cost sharing, subpart F exceptions, the R&D credit, the section 199 domestic production activity deduction, IP migration and valuation disputes, captive insurance company benefits, executive compensation, depreciation, capitalisation, deductions, withholding, independent contractors vs. employees, offshore accounts, partnership issues, and debt vs. equity. At present, Paul is litigating a section 199 issue for a mineral makeup company in a US tax court. Paul also has extensive state and local tax controversy experience with the California Franchise Tax Board, the California Board of Equalisation, the California Employment Development Department, and the California Unemployment Insurance Appeals Board, as well as with tax agencies in other states. His recent state cases have included state transfer pricing and valuation disputes, alternative apportionment, sales and use taxes for online sales, trust and estate issues, market-based sourcing, tax shelters, independent contractors vs. employees, and navigating voluntary disclosure programs in more than 40 states. Paul is recognised as a leading tax controversy adviser in the Tax Controversy Leaders Guide 2016. Paul has written several important works on US and international tax issues, and speaks and presents at professional tax seminars and symposia. He is the organiser of the annual Tax Controversy Seminar in Silicon Valley with the Tax Executives Institute. In addition, he has taught international tax classes as an adjunct professor at the LLM level. Prior to joining Mayer Brown in 2003, Paul practiced in Washington DC and San Francisco with two other prominent international law firms.
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Thomas J DriscollDeloitte Tax LLP 111 S Wacker Dr Chicago, IL 60606-4301 US Tel: +1 312 486 9564 Fax: +1 312 247 9564 Email: thosdriscoll@deloitte.com Website: www.deloitte.com Thomas J Driscoll, Deloitte US, is the partner in charge of Deloitte's international tax and transfer pricing practice. Thomas received a bachelor of science degree, with honours, from the University of Illinois Urbana-Champaign and a master's of science degree with distinction from DePaul University. Thomas specialises in the international tax, trading and treasury area, assisting multinational clients with financing strategies, tax efficient supply chain structuring, intellectual property planning strategies, hedging/risk management strategies, foreign tax credit planning, repatriation techniques and global tax minimisation. Clients served include US and non-US based multinational enterprises and financial market participants. Thomas is a frequent speaker on various topics involving federal income taxation and regularly speaks at Deloitte Tax national training, as well as external seminars and conferences. Thomas previously was an adjunct professor at the University of Chicago Graduate School of Business and taught at Northwestern University's JL Kellogg Graduate School of Management. Thomas is a certified public accountant and a member of the American Institute of Certified Public Accountants and Illinois Society of CPAs.
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Daniel DumezichDeloitte 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, Deloitte Tax LLP, is the managing director of federal tax controversy services. 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 5% 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 the highest distinction in 1989 from the John Marshall Law School.
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Jeffry ErneyDentons 1900 K Street NW Washington, DC 20006 US Tel: +1 202 496 7511 Website: www.dentons.com Jeffry Erney focuses his practice on tax litigation and dispute resolution. When representing clients faced with complex issues, Jeff draws on years of experience as a senior tax attorney for the Office of Chief Counsel with the Internal Revenue Service (IRS), as well as his background as a certified public accountant (CPA), to most effectively provide counsel. Jeff's background, both in private practice and as a governmental attorney, provides him with the tools to assess the strengths and risks of each issue, negotiate favourable settlements with the government and, if necessary, litigate the matter before the appropriate court. Jeff easily adapts to the venue in which he finds himself practicing, whether it is in front of the IRS or in trial, and does not lose focus of his clients' objectives throughout the representation process. Jeff has litigated more than 30 cases in the US Tax Court in addition to negotiating over 100 favourable settlements with the IRS at the examination, appellate and counsel level. Jeff is listed in The Best Lawyers in America guide (2007–2016) and the Ohio Super Lawyers (2008–2009, 2011–2015) and has been a frequent speaker before the Tax Executive Institute, the American Bar Association's tax section and the Cleveland Tax Institute. The US tax controversy practice and criminal tax practice was recognised by The Legal 500 in 2016 for outstanding work in contentious tax. Jeff was the panel chair for practice and procedure at Cleveland Tax Institute (2015, 2013, 2011, 2008, 2006) and has been the primary author of 'Representation Before The United States Tax Court' (Thomson West 2014) since 2007. 
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David ForstFenwick & 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. David's practice focuses on international corporate and partnership taxation. He is a lecturer at Stanford Law School on international taxation. He is an editor of and regular contributor to the Journal of Taxation, where his publications have included articles on international joint ventures, international tax aspects of mergers and acquisitions, the dual consolidated loss regulations, and foreign currency issues. He is a regular contributor to the Journal of Passthrough Entities, where he writes a column on international issues. David graduated with an AB (cum laude) Phi Beta Kappa, from Princeton University's Woodrow Wilson School of Public and International Affairs, and received his JD, with distinction, from Stanford Law School. He is included in Euromoney's Tax Advisers Expert Guide and in Law and Business Research's International Who's Who of Corporate Tax Lawyers (for the last seven years). David was named one of the top tax advisers in the western US by International Tax Review, is listed in Chambers USA America's Leading Lawyers for Business (2011-16), and has been named a Northern California Super Lawyer in Tax by San Francisco Magazine. David is a frequent chair and speaker at tax conferences, including the NYU Tax Institute, the Tax Executives Institute, and the International Fiscal Association.
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James FullerFenwick & 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 (2016). 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 International Tax Review's annual Americas Awards. Two of our tax partners were shortlisted by Euromoney at its Women in Business Law Awards 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 International Tax Review's World Transfer Pricing guide (2016). Five Fenwick tax partners have appeared in Euromoney's Transfer Pricing Expert Guide. 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.
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Jennifer FullerFenwick & 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, the only repeat winner. She also has been on Euromoney's 'Women in Business Law' shortlist four times for the award 'Best in Tax'. Jennifer's work during 2016 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, International Tax Review's leading lawyers in the western US, Euromoney's guide to the leading US tax lawyers, and International Tax Review's guide to the best tax advisers in North America.
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Erin G GladneyMayer Brown 1221 Avenue of the Americas New York, NY 10020-1001 US Tel: +1 212 506 2639 Fax: +1 212 262 1910 Email: egladney@mayerbrown.com Website: www.mayerbrown.com Erin Gladney is a tax controversy partner in Mayer Brown's New York office. Erin represents clients in all stages of federal tax controversies, including audits, administrative appeals, and litigation. Her experience includes controversies involving transfer pricing, advance pricing agreements, economic substance, substance-over-form doctrines, and summons enforcement. Erin also has experience defending against civil tax penalties and preserving taxpayers' attorney-client privilege and work product protection during audit, appeals, and litigation. Mayer Brown was recently named 'Tax Controversy Team of the Year' for the second consecutive year in the Legal 500 US Awards. "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 US edition. The firm is "regularly seen in the most high-profile controversy cases before the US Tax Court" and produced "yet another impressive run of work" in 2014.
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John T HildyMayer 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 Hildy 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.
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Cynthia HustadDeloitte 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 Website: www.deloitte.com Cindy Hustad, Deloitte Tax LLP, is the 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 the 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 US 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.
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Sharon Katz-PearlmanKPMG 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 an adjunct professor of law at NYU Law School, where she teaches Civil Tax Controversies and Litigation in the graduate tax (LLM) program. She is a frequent presenter at tax conferences and has published a variety of industry articles on various domestic and international tax topics. 
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John KeenanDeloitte Tax LLP 555 12th St NW Ste 400 Washington, DC 20004-1207 US Tel: +1 202 879 5605 Email: jkeenan@deloitte.com Website: www.deloitte.com John R Keenan, Deloitte Tax LLP, is the managing director of the tax controversy group in the Washington national tax office. 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, 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 US attorney, which allowed him to represent the IRS in the US 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 US 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.
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Andrew KimFenwick & 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 CBS Corporation v. United States in the US Court of Federal Claims, and is now serving as counsel in Analog Devices, Inc. v. Commissioner, and TBL Licensing LLC v. Commissioner in the US Tax Court. Andrew appears in Euromoney's world's leading tax advisers guide, International Tax Review's Tax Controversy Leaders guide, Law Business Research's Who's Who Legal: Corporate Tax, The Legal 500, and Chambers USA. 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.
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Thomas Kittle-KampMayer 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 Tom Kittle-Kamp is the co-leader of Mayer Brown's tax controversy and transfer pricing practice. His litigation experience includes the trial and appeal of major corporate cases involving Section 482 allocations, substance-over-form theories, intangible assets, debt-equity characterization, 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 extensive 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 licenses, sales and cost-sharing arrangements. He is the 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.
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Brian W KittleMayer Brown 1221 Avenue of the Americas New York, NY 10020-1001 US Tel: +1 212 506 2187 Fax: +1 212 849 5987 Email: bkittle@mayerbrown.com Website: www.mayerbrown.com Brian Kittle is co-leader of Mayer Brown's tax controversy & transfer pricing practice. Since joining the firm in 2006, Brian has represented clients in every facet of tax controversy and litigation. This includes IRS examinations and administrative appeals, through the litigation of highly complex tax controversies involving a broad range of international and domestic tax issues. This includes having a lead role in the recent Eaton transfer pricing US Tax Court litigation. His controversy experience also includes frequent use of IRS alternative dispute resolution tools, including pre-filing and advance pricing agreements, and defending taxpayers in summons enforcement proceedings. In addition to his controversy practice, Brian provides tax advice on related-party and highly-sophisticated transactions involving acquisitions and integrations. He also frequently speaks and writes articles about substantive and procedural tax issues. Brian has been repeatedly recognised as a rising star by International Tax Review's Tax Controversy Leaders guide and Super Lawyers. He was also recently recognised by Chambers USA as a noted practitioner for tax in New York. Before joining Mayer Brown, Brian served as an attorney advisor to Judge Joseph R. Goeke of the US Tax Court. This experience provided him with unique insight into the court's procedures and decision making process.
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Kenneth KleinMayer Brown 1999 K Street, NW Washington, DC 20006-1101 US Tel: +1 202 263 3377 Fax: +1 202 263 3300 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 2006-12. Before Mayer Brown, he worked at the IRS, first as attorney and then as assistant branch chief in the Legislation & Regulations Division and the General Litigation Division (1977-81), and later as the Associate Chief Counsel (Technical) (1988-90). Ken was an associate and then a tax partner at Cadwalader, Wickersham & Taft from 1981-88 and 1990-2002. He was also a fellow of the American Society of International Law (1976-77). Year after year Ken is recognised 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 2016 refers to Ken as "very experienced" and has named him a leading lawyer for six 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 six consecutive years. Ken is chair of the Washington International Tax Study Group, 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.
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Larry R LangdonMayer 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, 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, 1999–03; legislation and regulations division, office of counsel, 1964–68; and joint committee division, office of chief counsel, 1961–62). In the private sector, Larry has worked with leading firms such as Hewlett-Packard (VP, general transition manager, 1999; VP, tax, licensing and customs, 1978–99); Vetco (director of taxes and corporate secretary, 1976–1978); and the Ford Motor Company (senior tax attorney, general counsel's office, 1968–76). Larry also worked with the CARE organisation from 1962–64.
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Marc LeveyBaker & McKenzie 452 Fifth Avenue New York, NY 10018 US Tel: +1 212 891 3944 Fax: +1 212 310 1644 Email: marc.levey@bakermckenzie.com Website: www.bakermckenzie.com Marc Levey is a partner in the New York office of Baker & McKenzie. He has more than 35 years of experience in international taxation and is a nationally recognised expert in his field, particularly in structuring and defending transfer pricing strategies. He has frequently been acknowledged by Euromoney in its guide to the world's leading tax advisers and included in its Best of the Best global tax experts. Marc's practice focuses on transfer pricing and cross-border transactions; tax controversies and litigation; general corporate, international and partnership taxation, and restructuring multinational company's global operations. He has worked in various industries such as pharma/life sciences, financial institutions, energy, automotive, chemicals, electronics, consumer goods, gaming, fashion and luxury products. Marc serves on the US transfer pricing management committee, was the past chairman of the firm's global transfer pricing steering committee and is co-chair of the firm's luxury and fashion industry practice group. Marc previously served as tax attorney with the international tax ruling group of the National Office of the Internal Revenue Service (IRS) from 1975 to 1977. He acted as senior trial attorney with the Tax Division of the US Department of Justice from 1977 to 1981. He was the Special Attorney to the Attorney General of the US Department of Justice in 1982. Marc represents a wide range of clients in proceedings before the IRS and federal courts and has substantial experience in handling tax controversies. He has been, and still is, tax counsel to numerous significant Tax Court and US Claims Court cases and has also successfully negotiated conclusions to numerous IRS tax audits, appeals controversies, fast track appeals, Competent Authority matters and advance pricing agreements. Marc has been a featured speaker at numerous international tax seminars throughout the world. He is also the editor and author of tax treatises US Taxation of Foreign Controlled Business, co-author of International Transfer Pricing OECD Guidelines, Warren Gorman Lamont treatises, the co-author of Transfer Pricing: Rules, Compliance and Controversy 4th Edition, CCH Incorporated, the co-author of Transfer Pricing: Alternate Practical Strategies 890 Tax Management Foreign Income Portfolios (2001 and 2007), co-editor of Transfer Pricing and Dispute Resolution (IBFD 2011) and co-editor of Transfer Pricing and Intra-Group Financing (IBFD 2012). Marc has authored more than 180 publications over the last 20 years in leading global tax publications. He received his JD from University of Cincinnati College of Law in 1972 and his BS from Wilkes University in 1969. He received his LLM in taxation with honours from University of Miami Law School in 1983. He is admitted to practise in the states of New York, California and in the District of Columbia. 
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Darrin LitskyDeloitte Tax LLP 30 Rockefeller Plaza New York, NY 10112-0015 US Tel: +1 212 436 5760 Fax: +1 212 653 7883 Email: dlitsky@deloitte.com Website: www.deloitte.com Trained as a lawyer and a certified public accountant, Darrin Litsky, Deloitte US, is a transfer pricing specialist in the New York office. Darrin has a diverse background of 30 years of professional tax and accounting experience with industry, the Big 4 firms in 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. Darrin served as a team leader for four years with the IRS APA programme. During his time in government practice, Darrin has been substantively involved in hundreds of APA and mutual agreement procedure (MAP) requests involving a variety of different countries and industries. His current transfer pricing practice is primarily on APA and MAP request representations and audit defense. Darrin is a past chairman of the transfer pricing committee of the American Bar Association (ABA) tax section. Over the past 15-plus years, he served as the committee's chairman, vice chairman, led subcommittees on APAs, intercompany services, and important developments, and received the committee's Outstanding Service Award for 2003/04. In 2014, Darrin led an ABA taskforce that provided formal comments to the IRS on proposed procedures for obtaining an APA. Similarly, in 2005, Darrin was responsible for leading the ABA's formal comments to the IRS on the operation of the APA programme and provided oral testimony. In 2004 and 2006, Darrin led and participated in ABA task forces that provided formal comments on proposed and temporary Treasury regulations for transfer pricing of intercompany services. Darrin has given numerous speeches and presentations over the years at the ABA, the American Conference Institute, New York University, Tax Executive Institute, Broadband Tax Institute, CITE, ATLAS, and at IRS meetings and conferences on transfer pricing issues and APAs. He has written and co-authored several articles, including 'Strategic Considerations for Tax Controversy Risk Management and Double Taxation Avoidance' for International Tax Review (March 2016) with S Kumar and E Lesprit, and published 'Comments on Notice 2013-79 Proposed Procedures for Advance Pricing Agreements' with ABA members for the ABA on March 18 2014. Darrin holds a BS Economics degree (magna cum laude) from The Wharton School and a JD degree from Georgetown University Law Center. He is a member of the District of Columbia Bar and a certified public accountant (New York and New Jersey).
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James MastracchioDentons 1900 K Street NW Washington, DC 20006 US Tel: +1 202 496 7251 Website: www.dentons.com James (Jim) Mastracchio is a seasoned advocate who chairs Dentons' US tax controversy practice and criminal tax practice, which was recognised by Legal 500 in 2016 for outstanding work in contentious tax. Jim's work focuses on advising clients facing civil and criminal tax investigations. His work in civil tax disputes includes a wide range of civil tax reporting issues and the defence of structured products, tax-driven structures and their promotion. In the criminal tax arena, Jim represents clients facing tax fraud and evasion, conspiracy, obstruction, mail/wire fraud and monetary structuring charges. Jim has represented regulated financial institutions within and outside the US on a variety of civil and criminal tax investigations. He served as an independent examiner for a major Swiss banking institution, advised foreign financial institutions on the implementation of the Foreign Account Tax Compliance Act (FATCA) and the Organisation for Economic Cooperation and Development OECD reporting standards, and was lead counsel involving the first criminal tax investigation conducted by US authorities of a Cayman Island financial institution and its subsidiaries. Jim has also represented more than 400 individuals located across the globe who have participated in the Internal Revenue Service's (IRS) offshore voluntary disclosure programmes to resolve disputes involving previously undisclosed offshore accounts and structures. He regularly practices before the IRS (including the IRS Office of Appeals and IRS Criminal Investigation), the Department of Justice's tax division and various US attorneys' offices across the country, as well as in federal court. Jim has been recognised as a leading national tax controversy lawyer in the US Legal 500 Litigation guide and Super Lawyers. He is the author of the chapter 'Best Practices for Managing Tax Investigations' in 'Inside the Minds: Common Issues in White Collar Law', published by Thomson West Publishing (2007). He has been widely quoted in the national media, including by The New York Times, The Wall Street Journal, The Washington Post, MarketWatch, Bloomberg BNA, Tax Analysts, CCH and numerous other business and tax publications. Jim is a frequent speaker and panellist on civil and criminal tax matters.
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Wade McKnightDeloitte Tax LLP 1111 Bagby St., Suite 4500 Houston, TX 77002 US Tel: +1 713 982 4837 Fax: +1 713 427 4737 Email: wademcknight@deloitte.com Website: www.deloitte.com Wade McKnight, Deloitte US, is the managing director of Deloitte's tax controversy services practice for the South Central US. He has extensive tax controversies experience over a broad range of clients including several Fortune 100 energy companies, oil-field services companies, transportation companies, a Major League Baseball team, real estate management companies, engineering and construction firms, retailers, airlines, investment funds, and high-wealth individuals. Wade's tax controversies experience includes handling IRS case management for primarily large business and international industry cases and coordinated industry cases at both the examination and appeals levels. In addition, Wade regularly provides advice on general Internal Revenue Service (IRS) practice and procedure issues and assists clients with penalty abatements. Wade has assisted numerous clients with voluntary compliance submissions to the IRS related to withholding tax issues. He has also represented several clients during withholding tax examinations and has helped companies implement new tax and accounting processes and procedures to facilitate compliance with the withholding rules. Wade received his JD from the Paul M. Hebert Law Center at Louisiana State University. He has been admitted to the State Bar of Louisiana, State Bar of Texas and the US Tax Court. He is also an active member of the Texas State Bar Association and an inactive member of the Louisiana State Bar Association.
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Kristin M MikolaitisMayer Brown 1221 Avenue of the Americas New York, NY 10020-1001 US Tel: +1 212 506 2265 Email: kmikolaitis@mayerbrown.com Website: www.mayerbrown.com Kristin Mikolaitis is a partner in the tax controversy practice in Mayer Brown's New York office. Since joining the firm in 2008, Kristin has represented taxpayers at all stages of federal tax controversies, including during audit, in administrative appeals, and before federal courts. Kristin's controversy experience includes major corporate tax matters involving international tax and transfer pricing, substance-over-form disputes, economic substance issues, financial and leasing transactions, and civil tax penalties. Her litigation experience includes extensive trial work in the US Court of Federal Claims and the US Tax Court, as well as matters in various US Courts of Appeals. Kristin has also actively participated in the firm's pro bono efforts by representing individuals in tax, landlord-tenant, and estate planning matters. Kristin serves on the firm's committee on diversity and inclusion and the women's forum committee. In addition, from 2012 to 2015, she served on the leadership advisory committee of the National Women's Law Center. From 2009 to 2012, Kristin was based in the firm's Washington, DC office.
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Mark NehorayDeloitte 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, Deloitte US, is a senior partner, based in Los Angeles. Mark is consistently recognised as a leading transfer pricing adviser by publications including International Tax Review and Euromoney's Transfer Pricing Expert Guide. With more than 34 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 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 (e.g. entertainment and media, gaming, multi-level marketing, hi-tech, apparel, and non-profit). These projects have included both defensive work with respect to on-going Internal Revenue Service (IRS) audits and Competent Authority assistance, as well as planning studies and 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 their IRS transfer pricing examinations, another two US-based multinationals with their unilateral APAs, as well as assisting 10 foreign-based multinationals with their bilateral APAs. Since 2002, Mark has been the executive producer and the host of Deloitte's Transfer Pricing Dbriefs, a monthly internet program. He is a frequent speaker at US transfer pricing conferences sponsored by Bloomberg BNA. His recent publications include: the OECD Guidance on Transfer Pricing Documentation: Preparing for the New Global Standard; Bloomberg BNA's Tax Management Transfer Pricing Report (May 26 2016); Complying with OECD's Country-by-Country Reporting, Anaplan (November 2014); 'Integrating Tax and Treasury Operations with Transfer Pricing' in the CFO Journal (from the Wall Street Journal, August 27 2014); and International Tax Review's 'Transfer Pricing of Intangibles – Media and Entertainment' (December 2013), ('Turning Tech Investments into Value Repositories' (February 2011), and 'How APAs Fit into Today's Regulatory Landscape' (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.
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Larissa NeumannFenwick & 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 in International Tax Review's Tax Controversy Leaders guide and in Euromoney's Tax Advisers Expert Guide. Euromoney selected Larissa for inclusion in the Americas Women in Business Law Awards shortlist for 'Best in Tax Dispute Resolution' in 2014 and she was named the 2015 Rising Star: Tax. She was also named in the Silicon Valley Business Journal's '40 Under 40'. In 2016, Larissa was named a "Rising Star" in tax by Law360. Larissa frequently speaks at conferences for professional tax groups, including TEI, IFA, Pacific Rim Tax Institute, Bloomberg, and the ABA. She is the ABA international law tax liaison. Larissa has published several articles, including recently:
Fenwick has one of the world's top tax planning and tax transactional practices, according to International Tax Review, and is a first-tier firm in tax, according to World Tax. International Tax Review gave Fenwick its San Francisco Tax Firm Award a total of seven times and its US Tax Litigation Firm Award a total of three times. International Tax Review has also named Fenwick as the "Americas M&A Tax Firm of the Year".
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Shawn R O'BrienMayer 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 partner, who 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, the US Court of Federal Claims and US district courts. Shawn's tax controversy and litigation experience spans a broad range of areas, including transfer pricing controversies, debt v. equity issues, international withholdings, advance pricing agreements, tax shelter disallowances, R&D tax credits, excise taxes, and changes in accounting methods. Shawn advises foreign and domestic corporations, partnerships, MLPs, REITS, and LLCs seeking corporate and tax advice in connection with various types of foreign and domestic transactions, including 1031 exchanges, mergers and acquisitions, restructurings, divestitures, leveraged buyouts, structured financings, and oil and gas transactions. Shawn is a certified public accountant (CPA) licensed in Louisiana. Shawn serves on the Internal Revenue Service Advisory Council (IRSAC), where he is a member of the Large Business & International (LB & I) subcommittee of IRSAC. Shawn specialises on a variety of tax issues facing the energy industry including tax controversy, joint ventures, restructuring, acquisition and disposition of energy assets. Shawn served as chair of the Energy and Natural Resources Committee of the State Bar of Texas Tax Section from 2011 to 2013. According to International Tax Review's World Tax 2014, Mayer Brown's Houston tax practice is "known for its sophisticated transactional tax and tax controversy work".
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Edward C Osterberg JrMayer 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 Edward 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 mergers and acquisitions, tax-free reorganisations, corporate spin-offs and other divestitures, partnerships, international operations, including cross-border joint ventures with non-US partners, and inbound investment into the US by non-US investors. Chambers USA 2016 refers to Ed as "the dean of tax" and "very bright". Chambers USA also says: "He devotes a substantial part of his practice advising on the tax implications of high-value corporate matters, such as debt and equity instruments, spin-offs and restructurings".
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Kimberley PetersonDeloitte Tax LLP 225 West Santa Clara Street Suite 600 San Jose, CA 95113-2303 US Tel: +1 408 704 4041 Fax: +1 408 704 8074 Email: kimpeterson@deloitte.com Website: www.deloitte.com Kimberley Peterson, Deloitte US, is a managing director in the Silicon Valley office of Deloitte Tax'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 Internal Revenue Service (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.
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Irving PlotkinPwC 101 Seaport Boulevard Boston MA 02210US Tel: +1 617 530 5332 Email: irving.h.plotkin@us.pwc.com Website: www.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 Internal Revenue Service and Department of Justice 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.
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Keith ReamsDeloitte Tax LLP 980 9th Street Suite 1800 Sacramento, CA 95814-2738 US Tel: +1 415 783 6088 Email: kreams@deloitte.com Website: www.deloitte.com Keith Reams, Deloitte Tax LLP, 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 UK, and the US. Keith has assisted numerous multinational enterprises 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 US 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 of arts degree in economics from California State University Sacramento and a BS degree in chemical engineering from Stanford University.
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William A SchmalzlMayer 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 at Mayer Brown. 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 199, section 263A, 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 Parcel Service, RJR Nabisco, ConEd, Wells Fargo and Flextronics. Before joining Mayer Brown, William served as an articles editor at the Harvard Law Review and a clerk to the Honourable Robert Ainsworth, Jr., of the 5th Circuit Court of Appeals (1977-78).
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Ronald SchrotenboerFenwick & West Silicon Valley Centre 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 practises at Fenwick & West's Mountain View office. His published decisions include Xilinx, Inc. v. Commissioner, 125 T.C. 37 (2005), aff'd (9th Cir. 2010) (stock option amounts not required to be cost shared under § 482); Sun Microsystems v. Commissioner 69 T.C.M. 1884 (1995), (incentive stock option deduction qualifies for R&D credit); Appeal of Finnigan Corporation, CCH 401-797 (1990), (throwback rule is applied on a unitary basis; Appeal of Joyce overruled); and Petition of Intel Corporation, CCH 402-675 (1992), (technology transfers are not subject to California sales tax). 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.
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George SobaDeloitte Tax LLP 191 Peachtree St Ste 2000 Atlanta, GA 30303-1749 US Tel: +1 404 220 1153 Email: gsoba@deloitte.com Website: www.deloitte.com George Soba, Deloitte Tax LLP, is a principal of the transfer pricing practice. George has more than 18 years of experience with Deloitte, 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 US 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.
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David StallingsDeloitte Tax LLP 191 Peachtree Street NE Suite 2000, Atlanta GA 30303 US Tel: +1 404 220 1402 Fax: +1 404 631 8812 Email: dstallings@deloitte.com Website: www.deloitte.com David Stallings, Deloitte US, is the Deloitte global leader of business tax and international tax. The business tax professionals of Deloitte member firms specialise in consulting for multinational enterprises on tax, treasury and business issues and David is a frequent speaker on these topics. He spends a significant amount of time advising US-based multinational clients on matters such as structuring of subsidiaries and joint ventures, acquisition and disposition planning, cross-border financing, intercompany pricing, foreign tax credit planning, and global cash management. David spent one year on assignment in London where his clients were US-based and UK-based companies with multinational operations. Prior to joining Deloitte, David was in charge of the Southeast international tax practice at another large tax services firm. In 1987, David graduated from Oglethorpe University with a BBA in accounting. He is a certified public accountant in Georgia and a member of the International Fiscal Association.
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Scott M StewartMayer 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 Since joining Mayer Brown in 1989, Scott Stewart's practice has focused exclusively on tax disputes, including transfer pricing and intercompany debt 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 to 2016, Scott is described as "a talented litigator and corporate advisor" 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 USA 2016 describes him as "very knowledgeable on the subject matter, attentive to client needs and quick to learn the client's issues and business". Chambers also notes that he is "particularly adept at handling transfer pricing cases at all levels". Scott has extensive experience with deductibility of interest expense in related-party transactions, including debt vs. 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, which involved $3 billion in interest expense incurred from 1998 to 2000 and implicated an additional $6.5 billion in interest expense incurred from 2001 to 2007, were settled for 8% of the amount in dispute. 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 last two decades, such as National Semiconductor, Seagate Technology, Nestlé Holdings and United Parcel Service. Scott holds a JD from Harvard Law School and an MBA from the Johnson Graduate School of Management at Cornell University.
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David SwensonPwC 600 13th Street NW, Suite 1000 Washington, DC 20005 US Tel: +1 202 414 4650 Email: david.swenson@us.pwc.com Website: www.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 enterprises 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 enterprises (MNEs) 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 MNEs and the Internal Revenue Service (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 MNEs, 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.
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Joe TobinDeloitte Tax LLP 555 12th St. NW Suite 400 Washington, DC 20004 US Tel: +1 202 220 2081 Email: jtobin@deloitte.com Website: www.deloitte.com Joe Tobin, Deloitte US, is a senior manager in global transfer pricing at Deloitte's Washington national tax practice. Joe is very experienced in transfer pricing controversy and transfer pricing planning, especially in the area of cost sharing arrangements. Joe serves a wide variety of clients, specialising in intangible-centric industries such as the high-technology industry and the bio-pharmaceutical industry. Joe was the primary drafter of US Treasury's Regs. §1.482-7 (2011) and Regs. §1.482-7 (2013) on final cost sharing regulations. Joe was chosen by USCIB to comment on the OECD's 2015 discussion draft on cost contribution arrangements. Joe also helped the ABA and USCIB draft comments on Notice 2015-54 and the Section 367 temporary regulations and Section 482 temporary regulations released in September 2015. Joe was previously senior counsel at the Department of Treasury, within the Internal Revenue Service (IRS) office of associate chief counsel (international) (branch 6) (transfer pricing) in Washington DC, where he was the national office reviewer in charge of many of the high-profile transfer pricing litigation cases involving transfers of intangibles. Joe also advised IRS exam and field counsel on hundreds of contentious transfer pricing audits that went to IRS appeals. Joe has also commented on several versions of the draft IRS appeals settlement guidelines on cost sharing buy-ins, which have never been published. Joe was also known as the "go to" person for advanced pricing agreements (APAs) with complex technical issues involving cost sharing arrangements (CSAs), and he advised on several such APAs with CSAs. Joe has spoken at numerous conferences, webcasts, and training sessions on transfer pricing and cost sharing. He has been a member of the Georgetown Law Adjunct Faculty since 2013, where he co-teaches a class on transfer pricing. Joe received a master's degree in tax law from New York University in 2007, a JD from the University of Virginia in 2005, and a Bachelor of Arts in Philosophy and Political Science from Reed College in 1995. Joe is licensed to practice law in Nevada and New York
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Gary WilcoxPwC 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: www.pwc.com/taxcontroversy Gary Wilcox is a principal with PwC 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 Internal Revenue Service (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 the 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. Prior to that, he served as deputy chief counsel (technical) in the IRS Office of Chief Counsel and, earlier, 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 Bloomberg BNA Tax Management Portfolio entitled 'Corporate Acquisitions – (A), (B), and (C) Reorganizations'. 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.
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Joel V WilliamsonMayer 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 co-chair of Mayer Brown's tax controversy practice. He has tried in excess of 60 tax cases to judicial opinions and an unprecedented seven transfer pricing cases, including Eli Lilly, GD Searle, Westreco (Nestlé), Seagate Technology, National Semiconductor, United Parcel Service and most recently in 2015 Eaton Corporation. Continuing his history of handling the largest of transfer pricing cases, Joel is serving as trial counsel in the mega multi-billion dollar Guidant LLC cases. Also, in 2015, Joel was a lead trial counsel in the multi-billion dollar Exelon like-kind exchange case. In the international tax area, Joel has litigated subpart F, constructive triangular dividend and R&D moratorium issues, Brazilian and other foreign tax credits for banks, as well as foreign versus domestic-source income IRC § 863(b) questions. In addition, Joel has litigated IRC § 338 corporate acquisition related issues, like debt vs. equity for Nestlé. Joel was a lead trial counsel in the mega Tyco debt vs. equity cases, which were favourably settled for Tyco. 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 (Eaton). Joel has been recognised by Chambers USA as a leading lawyer every year since 2003 to 2016. Chambers USA said Joel is "a dean of the tax controversy Bar, revered for his 'spectacular courtroom manner and skills'." In addition, Legal 500 recognised him as a leading lawyer in 2011 to 2016. Joel served as an officer in the US Army from 1970 to 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 to one of 20 special trial attorneys located throughout the US. Joel joined Mayer Brown in 1986 as a partner.
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Todd WolosoffDeloitte Tax LLP 1633 Broadway New York, NY 10019-6754 US Tel: +1 212 492 4890 Email: twolosoff@deloitte.com Website: www.deloitte.com Todd Wolosoff, Deloite Tax LLP, is the 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 enterprises 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 US 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 US. 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 of 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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Robert H Albaral
Baker & McKenzie
Gregory Barton
PwC
Peter Blessing
KPMG
Thomas Borders
McDermott Will & Emery
Kim Boylan
White & Case
Steven S Brown
Martin, Brown, Sullivan, Roadman & Hartnett
Thomas Callahan
Thompson Hine
Nathaniel Carden
Skadden, Arps, Slate, Meagher & Flom
George M Clarke
Baker & McKenzie
Jerold Cohen
Sutherland Asbill & Brennan
Erin Collins
KPMG
Andrew Crousore
Baker & McKenzie
Michael Danilack
PwC
Lucas Dante
KPMG
Michael Desmond
Law Offices of Michael J Desmond
Mike Dolan
KPMG
Carol Dunahoo
Baker & McKenzie
Michael Durney
Law Offices of Michael C Durney
Elizabeth Erickson
McDermott Will & Emery
David Ernick
PwC
Miriam Fisher
Latham & Watkins
Sean Foley
KPMG
Scott Frewing
Baker & McKenzie
Jasper G Taylor III
Norton Rose Fulbright
Stephen Gardner
Cooley
George Gerachis
Vinson & Elkins
Fred Goldberg Jr
Skadden, Arps, Slate, Meagher & Flom
Charles Hall
Norton Rose Fulbright
Rob Hanson
EY
Lawrence Hill
Shearman & Sterling
Thomas Johnston
Shearman & Sterling
Maria Jones
Miller & Chevalier
Richard Jones
Sullivan & Worcester
Roger Jones
McDermott Will & Emery
Phil Karter
Chamberlain Hrdlicka White Williams & Aughtry
Kevin Kenworthy
Miller & Chevalier
Donald Korb
Sullivan & Cromwell
Stephen Kranz
McDermott Will & Emery
Frank Lavadera
KPMG
Gregg Lemein
Baker & McKenzie
Patricia Lewis
Caplin & Drysdale
Jerome Libin
Sutherland Asbill & Brennan
Thomas Linguanti
Baker & McKenzie
Raj Madan
Skadden, Arps, Slate, Meagher & Flom
John Magee
Morgan Lewis & Bockius
Jane Wells May
McDermott Will & Emery
David Nagle
Sullivan & Worcester
Deborah Nolan
EY
Kathryn O'Brien
PwC
Mark Oates
Baker & McKenzie
Pam Olson
PwC
Emily Parker
Thompson & Knight
Jean Pawlow
McDermott Will & Emery
Martin Press
Gunster
Jose Manuel Ramirez
KPMG
Patricia Anne Rexford
Baker & McKenzie
David Rosenbloom
Caplin & Drysdale
Leslie Samuels
Cleary Gottlieb Steen & Hamilton
Paul Schick
Baker & McKenzie
Leslie Schneider
Ivins Phillips & Barker
William Sharp
Sharp Partners
Barry Shott
PwC
Sanford Stark
Morgan Lewis & Bockius
Douglas Stransky
Sullivan & Worcester
Brian Trauman
KPMG
Juan Vasquez, Jr
Chamberlain, Hrdlicka, White, Williams & Aughtry
Mario Verdolini
Davis Polk & Wardwell
Duane Webber
Baker & McKenzie
Todd Welty
McDermott Will & Emery
Daniel White
Baker & McKenzie
B John Williams
Skadden, Arps, Slate, Meagher & Flom
Robert Willmore
Crowell & Moring
Diana Wollman
Cleary Gottlieb Steen & Hamilton
Steven Wrappe
KPMG
Russell Young
Baker & McKenzie
Shanwu Yuan
Baker & McKenzie
Thomas Zollo
KPMG
