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Transfer pricing
Aptis Global

Aptis Global began on April 1, 2017, as an integrated international tax and transfer pricing firm with more than 150 years of combined experience. With offices in San Diego, Tijuana and Brussels the firm offers global expertise.

The team’s experience advising multinational companies can be seen in its experience assisting a US multinational company to design multiple IP strategies and thus conceptualising and creating numerous options models. This allowed the company to consider aligning certain IP with its operational transformation timeline and the shifting global commercial and regulatory landscape. The firm has also worked with a client to design a unique commodities transfer pricing framework that will leverage the existing legacy systems and aid in designing the optimal data requirements for a future system.

Baker McKenzie

Baker Mckenzie’s transfer pricing practice offers services in planning, compliance, controversy, APAs, and MAPs. Its  practice includes more than 40 partners, counsels, associates, economists, analysts and other professionals. It is helmed by Salim Rahim, who serves as the chair of the firm’s North America transfer pricing sub-practice group.

In the last year, the firm has added Debra Doyle, Jack Newlin, Erin Gladney, Michael Jaffe as partners, and Michael Keskonis as of counsel.

BaseFirma

BaseFirma’s Miami office is the US arm of a consolidated international transfer pricing firm with offices in The Netherlands, Mexico, Colombia, Ecuador, Argentina, Venezuela, Brazil, Chile and Peru. The firm works as a fully integrated international team of transfer pricing professionals. It is led by Fabian Alfonso in Miami. In the last year, it has added a Brazilian office to help further strengthen its Brazilian transfer pricing practice.

The firm’s diverse transfer pricing practice can be exhibited in the team’s representation of a developer in a transfer pricing system design case in creating a new cross-border transfer pricing system for a company dedicated to developing cashless payments and financial transactions systems.

Bennett Thrasher

Atlanta-based Bennett Thrasher has had an established transfer pricing practice for just over a decade, with the firm’s transfer pricing practice being led by partner Benjamin Miller since early 2014.

Bennett Thrasher has extensive experience designing transfer pricing systems for multinationals in North America, Europe and Asia, and the firm receives many referrals from DFK International, a global association of independent accounting firms in over 80 countries.

In the last year, the team has added James Pickett as director of controversy and Laurie Bizzell as senior manager for the firm.

Deloitte

Deloitte maintains its excellent reputation year after year by having one of the premier transfer pricing practices in the nation. John Wells is the firm’s US transfer pricing leader. Steve Kimble is the chairman and executive officer of the group.

The team specialises in business model optimisation, tax structuring, M&A, multistate tax services, cross-border tax and tax compliance. It also advises companies facing tax complexity as well as those involved in intercompany cross-border transactions. The team specialises in helping companies address tax compliance risks by aligning practical transfer pricing approaches with their overall global business operations.

The firm’s international tax and transfer pricing practice, headed by John Womack, consists of more than 1,300 professionals and works with a variety of sectors including health, insurance and investment management.

Dentons

The Dentons transfer pricing practice advises multinational companies regarding compliance with US transfer pricing rules, including transfer pricing documentation requirements and the production of foreign-based documents, as well as resolving transfer pricing disputes and using dispute resolution mechanisms under income tax treaties.

DLA Piper

DLA Piper’s transfer pricing team is a global operation consisting of lawyers, economists, and certified tax advisers and helps to advise on the transfer pricing rules of all countries with developed transfer pricing regimes, as well as work with companies that range from large multinationals to emerging companies looking to expand internationally. The team is involved in a variety of industries including apparel and footwear, information technology, software, life sciences, pharmaceutical, medical instruments, biotech, energy, shipping and logistics, financial services, automotive and non-durables including luxury goods, food, and beverages.

The firm’s extensive experience advising clients around the world can be exhibited in its negotiating a renewal for an APA relating to the pricing of a purchase product and component purchases of products manufactured in Japan and sold in the US.

Epsilon Economics

Epsilon Economics is a Chicago-based economic consulting and transfer pricing firm, with expertise in planning, documentation, compliance, dispute resolution and tax valuation. The team is led by Jill Kosonen.

In the last year, the firm has added David Marshall, former director of the financial markets research group at the Financial Reserve Bank of Chicago; Roland Eisenhuth, an economics professor from Oregon State University; John Plumpe, a specialist in the economics aspects of intellectual property; and, Scott Phillips, a CPA and expert on the economic aspects of trademarks.

Fenwick & West

Fenwick & West’s transfer pricing practice is an important part of its tax dispute resolution practice, and has handled transfer pricing court cases that include Apple, Xilinx, Hitachi, Limited Brands, and AOC International, among others. The team also has experience assisting clients with APAs, and is active in helping to establish and document transfer pricing policies for clients reflecting changing rules in many parts of the world. It also works in a variety of industries, including, high tech, pharmaceutical, retail and media.

The firm offers services in areas such as transfer pricing disputes and APAs. It has assisted clients with developing transfer pricing policies that reflect the changing tax regimes in many parts of the world that require more extensive documentation. It has also published leading articles in the transfer pricing area and is in discussions with government officials on matters relating to transfer pricing policy. Fenwick & West has served as co-counsel in cases in Japan, Denmark and Canada.

Over the past year, the team has acted as counsel in the Analog Devices v Commissioner case. This involved a transfer pricing matter decided in favour of Analog Devices in a "reviewed by the court" decision. It has also handled transfer pricing court cases that involved Apple, Xilinx, Hitachi, Limited Brands, AOC International and Adaptec, among others.

Mayer Brown

Mayer Brown’s transfer pricing practice remains one of the most robust in the country, with a particular reputation for employing innovative techniques in the representation of corporate taxpayers in transfer pricing planning, audits, IRS appeals, competent authority and litigation. Many of the team’s professionals have had extensive experience at the IRS before joining the Mayer Brown team. The firm’s transfer pricing practice is a major component of the tax controversy practice in each of its Chicago, New York, Washington, Houston and Palo Alto offices.

The firm’s innovative experience in dealing with some of the biggest transfer pricing controversies to date is exhibited in its representation of the Eaton Corporation in its ground-breaking and rare victory in the US tax court rendered on July 26, 2017, where the IRS had cancelled two APAs with Eaton. These agreements governened the transfer pricing of products Eaton manufactured in its Puerto Rico and Dominican Republic facilities and sold to its US subsidiaries. To cancel the agreement, the IRS made dozens of allegations of impropriety, including misrepresentations and misstatements of material facts. The court vindicated Eaton on all allegations, eventually determining that the IRS’s cancellation of the APAs was an abuse of discretion and reaffirming in strong terms that the IRS must abide by the terms of its agreements with taxpayers. This case was notable because Eaton was the first taxpayer ever to challenge the IRS’s cancellation of an APA.

In the last year Gary Wilcox, a partner in the firm’s Washington DC office and expert in tax controversy and transfer pricing matters, joined the team.

Miller & Chevalier Chartered

Miller & Chevalier Chartered began as the nation’s first federal tax practice in 1920, and has since maintained close relationships with its corporate clients for almost a century. The firm’s transfer pricing practice is among the largest and most successful across the US, and its multidisciplinary practice assists clients across a wide array of industries including pharmaceuticals, consumer products, electronics, telecommunications and natural resources. Its practice offers services in transfer pricing planning, controversy transfer pricing adjustments and APAs.

The firm’s extensive experience in some of the largest transfer pricing matters to date is exhibited in its representation of Coca-Cola as co-counsel before the US Tax Court in a high-stakes transfer pricing dispute. The suit was filed in response to an IRS determination that Coca-Cola owed $3 billion of additional income taxes for the years 2007-2009. It was eventually ruled in favour of the client, and that the IRS was incorrect to deny the company more than $138 million in foreign tax credits from taxes paid by its Mexican branch to the Mexican government. The foreign tax credit issue is part of the company’s case against the IRS concerning a $9.4 billion transfer pricing adjustment related to its licensing of intangible property to foreign affiliates.

Morgan Lewis & Bockius

The Morgan Lewis & Bockius transfer pricing team has represented US and foreign multinational enterprises in a wide range of industries, including technology, e-commerce, pharmaceuticals, medical devices, energy and financial services, in all aspects of the transfer pricing planning and controversy processes.

The firm’s involvement in some of the largest transfer pricing matters to date is shown in its representation of Amazon in a dispute before the US Tax Court regarding valuations related to the client’s creation of a European headquarters. Following a six-week trial, the court ruled for Amazon in March 2017. As a $1.5 billion transfer pricing dispute, with a matter value of $3.5 billion, this case represented one of the largest transfer pricing cases ever litigated, and the first transfer pricing case involving e-commerce. Morgan Lewis’s transfer pricing team also represented Coca-Cola.

In the last year, the firm has added Thomas Linguanti, Jenny Austin, Adam Beckerink, Michael Liu, Matthew Mock, and Joshua Richardson as partners – all joining from Baker McKenzie – as well as Michelle Andrighetto as counsel from PwC, Nelson Yates counsel from Baker McKenzie and Justin Cupples as counsel from EY. Jason Dimopoulos has also been added as a senior associate from Baker McKenzie.

Norton Rose Fulbright

Skadden Arps Slate Meagher & Flom's transfer pricing practice offers services in international structuring, planning and audit issues, cross-border transactions and managing tax controversies, among other things.

Nathaniel Carden is a partner at the firm's Chicago office. He has assisted clients with transfer pricing planning and pre-audit issues arising from cross-border intangible property, and has provided advice and related documentation on cross-border transactions.

Plante & Moran

Headquartered in Denver, the transfer pricing team at Plante & Moran - formerly EKS&H - began in 2013 and has been headed by Keri Thiessen ever since. Its practice is composed of CPAs, economists, and attorneys focused on mid-market companies engaged in inbound and outbound transactions with affiliates. It offers planning and documentation services as well as risk assessment, transaction due diligence and dispute resolution services. The majority of the firm’s clients are US-based multinationals and inbound clients from the UK, Australia and China.

The firm’s experience in transfer pricing consultation can be exhibited by its representation as lead advisor for a Colorado-based company in identifying a transfer pricing policy that would create transparency in jurisdictional profitability, allowing its machine business to operate at arm’s length and motivate employees to generate profitable business.

Skadden Arps Slate Meagher & Flom

Skadden Arps Slate Meagher & Flom's transfer pricing practice offers services in international structuring, planning and audit issues, cross-border transactions and managing tax controversies, among other things.

Nathaniel Carden is a partner at the firm's Chicago office. He has assisted clients with transfer pricing planning and pre-audit issues arising from cross-border intangible property, and has provided advice and related documentation on cross-border transactions.

Sullivan & Cromwell

The firm’s transfer pricing practice is a part of it greater tax practice, and is a highly specialised and focused group out of New York and London.

Ron Kramer is the head of the tax group. He is an experienced practitioner and has strong expertise in capital markets strategies, acquisitions and dispositions, particularly relating to cross border transactions. Another member of the firm is Donald Korb, who was the former chief counsel for the IRS. Korb has assisted clients with developing and evaluating transfer pricing strategies, documentation, defence and negotiating APAs with the tax authorities. He has also published literature on tax and transfer pricing-related issues.

The firm was pleased over the past year to promote Isaac Wheeler as a partner.