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Transfer Pricing Portfolios Library

Product Code: TMLW31
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Bloomberg BNA's Transfer Pricing Portfolios Library provides analysis and news on the highly complex and quickly evolving area of transfer pricing.  This Library has three main components:  the Portfolios, featuring in-depth analysis of renowned transfer pricing experts; the Transfer Pricing Report providing biweekly news and developments; and instant access to relevant source documents and practice tools.

Written by leading practitioners in this highly complex and constantly evolving practice area, the Transfer Pricing Portfolios Library provides everything necessary to manage intercompany prices to avoid penalties as they exchange goods or services between related companies located in different countries.

What it helps you do:

Benefit from analysis and perspective from leading U.S. and foreign practitioners and interviews with government officials.  The Transfer Pricing Report, included in this Library, provides U.S. and Foreign government officials, interpretations of laws they are enforcing in transfer pricing and permanent establishment areas.

Major Topics Covered:

  • Introductory materials on transfer pricing
  • Section 482 Regulations and Rulings
  • Transfer pricing judicial decisions, strategy and outcomes
  • Economic, managerial and accounting principles in transfer pricing
  • Transfer pricing records and information
  • Alternative practical strategies in transfer pricing
  • Section 6662 Transfer Pricing Penalties
  • Advance pricing agreements
  • Cost-sharing arrangements
  • Transfer pricing rules of France, U.K., Germany, Denmark, Belgium, Italy, Sweden, Switzerland, Canada, Mexico, Japan, Korea, Australia, and Brazil
  • OECD Transfer Pricing Rules and Guidelines

Product Structure

  • Portfolios: In-depth analysis of specific transfer pricing topics.
  • Notification: Current Reports and regular Special Reports providing news and developments.
  • Practice Tools: Federal Tax Calendar, working papers, tables, charts and lists
  • Source Documents: Primary source material including Laws & Regulations, Agency Documents, and Cases.

Formats and Frequency

Available in print and on the web. Contents vary by format.

The Portfolios are updated regularly. The Transfer Pricing Report is issued biweekly. The International Journal is updated monthly.  Insights & Commentary (International) is produced regularly. E-mail summaries, providing the highlights and table of contents for each Report, with URLs to full text articles and documents, are also available.  

Akira Akamatsu
 Akira Akamatsu, Esq. served at the National Tax Agency (NTA) National Office and the Tokyo Regional Taxation Bureau from 1975 to 1990. His last position was as a NTA International Examination Section Chief. Akamatsu has published articles widely in major Japanese and international tax journals and lectured both in Japan and overseas. He was honored with a special award from the Japanese Tax Institute for his book International Tax Principles and Japanese International Tax Law (Zeimu Kenkyukai, 2001).
Reuven S. Avi-Yonah
Reuven S. Avi-Yonah (B.A., Hebrew University, 1983; Ph.D., Harvard University, 1986; J.D., Harvard Law School, 1989) is Assistant Professor of Law, Harvard Law School, where he teaches domestic and international taxation. Mr. Avi–Yonah is a member of the New York and Massachusetts bars and co–chairs the tax policy committee of the New York State Bar Association Tax Section. He participated in preparing the Tax Section's reports on proposed legislation on amortization of intangibles and has published several articles and comments on the leading Supreme Court case in this area, Newark Morning Ledger Co. v. United States, 113 S. Ct. 1670 (1993). 
David B. Bailey
David B. Bailey, Duke University (A.B. 1994); Georgetown University Law Center (J.D. 1999); New York University School of Law (LL.M. in Taxation, 2001); Executive Editor, The Tax Lawyer; Graduate Editor, Tax Law Review.
Tony Beare
Tony Beare is a Tax Specialist with Slaughter & May in London, England.
Nathan Boidman
 Nathan Boidman, Esq., Davies Ward Phillips & Vineberg, Montreal, Canada.
Philip Carmichael
 Philip Carmichael is a principal economist in Baker & McKenzie's New York office. He has advised several US-based companies on global transfer pricing including transfer pricing analysis, planning, documentation and dispute resolution. He has also coordinated and prepared documentation to serve the needs of tax authorities across different jurisdictions. In transfer pricing disputes, he has assisted in the preparation of economic analyses and responses to information requests, as well as advised on strategy. Prior to joining Baker & McKenzie, Mr. Carmichael was a principal in the economic and valuation services practice of KPMG LLP.
Patrick Cauwenbergh
Patrick Cauwenbergh is an International Tax Partner with Deloitte Belastingconsulenten and is the head of the transfer pricing and tax effective supply chain group within Deloitte. He has participated in transfer pricing assignments for Europe-based companies (including many of the largest Belgian controlled groups) regarding their relations with other EU-countries, Eastern Europe countries, the United States, Japan, etc. He obtained a Ph.D. in law on “international transfer pricing” at the University of Antwerp, where he is a Professor of International Tax Law, and obtained a Master in International and European Taxation at the Ecole Supérieure des Sciences Fiscales in Brussels. In addition, he has prior experience in the corporate tax aspects of the financial industry (hybrid financing, global trading, cash pooling, charge out of corporate fees, cost sharing, leasing transactions, etc.). He has published two monographs and authored several articles on international transfer pricing and is Guest Professor at the Universities of Gent and Leuven and a regular speaker at seminars on related topics. 
Clark J. Chandler
Clark J. Chandler, Dickinson College, B.A. (1974); University of Michigan, M.A. and Ph.D., Economics (1978). Dr. Chandler is a principal with KPMG LLP's Washington national Tax/Economic Consulting Services practice. He has testified extensively and worked for both tax authorities and multinational corporations in the area of international transfer pricing.
Jenny Cottrell
Jenny Cottrell is with Stephenson Harwood in London, England.
Robert E. Culbertson
Robert E. Culbertson, Yale University (B.A. 1979), Harvard University (J.D. 1982). 
Nicasio J. del Castillo
Nicasio del Castillo, Universidad del Uruguay; Harvard Law School (International Tax Program, 1970); member, AICPA Subcommittee on International Taxation and International Fiscal Association. 
William G. Dodge
William G. Dodge, University of Georgia, Master of Accountancy (Tax) (1979); Walsh College, B.A. (1976); Director, Global Transfer Pricing Team; Co–Director, U.S. Transfer Pricing Team, Deloitte & Touche LLP, Washington, D.C. Formerly Partner–in–Charge, U.S. Corporate Tax Group, Deloitte & Touche, London, England. Member, Tax Management Advisory Board (Transfer Pricing). Mr. Dodge is regular speaker at seminars and has worked in New York, London, and Tokyo where he served many of Deloitte & Touche's largest U.S. and non–U.S. clients. 
Michael C. Durst
Michael C. Durst, Williams College (B.A. 1975), M.I.T. (M.S. (Econ.) 1978), U.Cal. Berkeley (J.D. 1981), Harvard University (LL.M. 1985). 
Graham Earles
Graham Earles is a Tax Specialist with Slaughter & May in London, England.
Stephen M. Edge
Steve is a corporate tax partner at Slaughter and May where he has an extensive tax consultancy practice which includes advising on business and transaction structuring, dealing with in-depth tax investigations and tax litigation and doing a large amount of work in the transfer pricing/thin capitalisation area.
Christian Emmeluth
Christian Emmeluth obtained an L.L.B.M. from Copenhagen University in 1977 and became a member of the Danish Bar Association in 1980. During 1980-81, he studied at the New York University Institute of Comparative Law and obtained the degree of Master of Comparative Jurisprudence. Mr. Emmeluth was a partner in the law firm of Koch-Nielsen & Gronborg based four years in London but is now based in Copenhagen.
David Garcia Fabregat
Bruno Gouthiere
Bruno Gouthiere, Ecole Nationale d´Administration, the University of Paris, Master in Law and BS in Economics, and the Institut d'Etudes Politiques of Paris; partner with CMS Bureau Francis Lefebvre, international tax department, since 1989; previously, he was acting as Chief of Staff, International Tax Relations, Tax Policy Department, Ministry of Finance; author of reference books in international tax law, such as “Les Impôts dans les affaires internationales”, "Les Holdings", "Transfer Pricing Rules and Practice in France" (Tax Management, BNA), "Advance Rulings in France" (IBFD), "The International Guide to Holding Companies" (IBFD), co-author of various books on “Wealth” (Memento du Patrimoine), “Civil Companies” (Memento Sociétés Civiles), and of numerous articles in French and foreign legal, tax and financial reviews;  member of various associations of tax practitioners such as the International Fiscal Association (“IFA”) and the Fiscal Committee of the European Fiscal Confederation (“CFE”).
Karl L. Kellar
Woo Taik Kim
Woo Taik Kim, Seoul National University (B.A., 1970); Columbia University (M.B.A., 1972); tax partner, Kim & Chang, Seoul; Member, Korean Institute of Tax Attorneys, Korean Institute of Certified Public Accountants, New York State Society of Certified Public Accountants, International Fiscal Association. 
Kenneth J. Krupsky
Kenneth J. Krupsky, Tax Partner, Jones Day (Washington, DC); Columbia LawSchool (J.D. 1972; Harlan Fiske Stone Scholar; International Fellow;Columbia Law Review; Comments and Case Notes Editor, Columbia Journal ofTransnational Law); Columbia College (B.A. in Philosophy 1969; NationalMerit Scholar). Served as Deputy Assistant Secretary of the Treasury forTax Policy, U.S. Treasury Department in President Clinton's second term,Chair of the International Tax Committee of the District of Columbia BarAssociation, and Adjunct Professor at Georgetown University Law Center.Member of Tax Management International Journal's "Panel of LeadingPractitioners" and regularly contributes to that journal.  Otherpublications include:  Joint Ventures with International Partners (coauthor, Butterworth 1994); and International Joint Ventures coauthor, Federal Publications 1986; 2d ed. 1988).  Regularlylisted as a leading tax lawyer in Chambers USA, Euromoney's InternationalTax Review (one of the "world's leading tax advisers" and "world's leadingtransfer pricing advisers"), and Super Lawyers. 
Marc M. Levey
Zion Levi
Harrison B. McCawley
Harrison B. McCawley, A.B., Princeton University (1948); LL.B., Harvard Law School (1951); Attorney, Tax Division, Department of Justice (1955–60); Staff Attorney, Joint Committee on Taxation (1960–72); Refund Counsel, Joint Committee on Taxation (1972–80). 
Jerrie V. Mirga
 Jerrie Varrone Mirga, College of William & Mary, B.A. (1979); George Washington University, MBA (1985) and post-MBA Certificate (2001); Vice President, Economic Consulting Services, LLC. Ms. Mirga advises clients on transfer pricing issues involving tangible and intangible property for planning, documentation and audit purposes.
Michael F. Patton
Michael F. Patton;  University of Maryland (B.A. and J.D. with honors, Order of the Coif), Georgetown University Law Center (LL.M., Taxation); was editor and a major contributor to the Treasury/IRS Transfer Pricing White Paper; was a member of the Treasury/IRS study group to revise the competent authority function;  worked extensively on the OECD Multilateral Treaty on Mutual Administrative Assistance in Tax Matters and the U.S.-Bermuda Tax Convention; was the lead  U.S. Treasury negotiator in many negotiations with foreign governemnts for tax information exchange agreements under the Caribbean Basin Initiative;  named one of the Best of the Best U S transfer pricing advisors as well as one of the leading Asia Pacific tax advisors by Euro Money and the International Tax Review; has been named as a “Highly Recommended” tax advisor by the International Tax Review; member, Editorial Advisory Board of Tax Management, Inc; contributor to the Tax Management International Tax Journal, the Transfer Pricing Reporter, and other publications; is a Principal with Ernst & Young, a member of the International Tax Services Group in the National Tax Department. 
Horacio Pena
Irving H. Plotkin
Irving H. Plotkin, Wharton School, University of Pennsylvania, B.S.; Massachusetts Institute of Technology, Ph.D. in mathematical economics. Dr. Plotkin is Managing Director of the Boston Tax practice of PricewaterhouseCoopers; for many years previous, he was Vice-President for Forensic Economics at Arthur D. Little, Inc. Dr. Plotkin has designed and conducted research studies on various topics including the effects of government regulation, self-regulation, industry efficiency and risk taking. Dr. Plotkin lectures frequently on economic and regulatory issues, and based on his research work, has presented expert testimony in the Tax Claims, U.S. District, and State Courts on behalf of taxpayers and the IRS in a number of high-profile tax disputes (including Du Pont, UPS, DHL, ACM, Bausch and Lomb, The Limited, Dow, and the captive cases) and has testified before U.S. congressional committees and federal and state commissions. 
Bob Ramage
Bob Ramage is a Tax Specialist with Slaughter & May in London, England.
George H. Soba
George H. Soba, Esq., New York University School of Law, LL.M. (Taxation) (1982); University of Toledo College of Law, J.D. (cum laude) (1981); Franklin and Marshall College, B.A. (1978); formerly IRS Tax Counsel, Brooklyn District Counsel Office and Senior Attorney–Advisor in the Office of Associate Chief Counsel (International).
Manuel F. Solano
Manuel F. Solano, Universidad Autonoma de Centro America, Costa Rica; Youngstown State University (B.S., 1986); Georgetown University Law Center (J.D., 1989); member, American Bar Association; member, New York State Bar. 
Gary M. Thomas
Gary M. Thomas, B.A., University of Washington, 1973; J.D., Harvard Law School, 1977; Asia University, Masters of Japanese Law/Taxation (1989) and Masters of Japanese Accounting (1994); Partner, White & Case LLP, Tokyo, Japan; admitted in Japan as licensed tax attorney (zeirishi); member of Tokyo Zeirishi Association, California State Bar Association, and Dai-ni Tokyo Bar Association; speaker on Japanese international tax issues; author, articles on Japanese taxation in the United States, Japan and Europe.
Monique van Herksen
Bart Van Honsté
Bart Van Honsté is a manager for the Brussels transfer pricing group of Deloitte & Touche where he works on transfer pricing issues, including those related to reorganizations, permanent establishments, and e-commerce. He has been involved in several arbitration procedures under the EU Arbitration Convention. Mr. Van Honsté obtained a degree in Economic Sciences at the University of Leuven (1993), a degree in Law at the University of Antwerp (1997), and a Master in Taxation at the University of Brussels (Solvay). He is a regular speaker at transfer pricing seminars and is the author of several publications with respect to transfer pricing in international and Belgian tax journals.
John P. Warner
 John P. Warner, B.A., George Washington University (1971); J.D., University of California, Berkeley (Boalt Hall) School of Law (1977); Member, American Bar Association Section of Taxation; Chair, American Bar Association Section of Taxation Transfer Pricing Committee (2008-2010); Admitted to practice, United States Tax Court, United States Court of Federal Claims, United States Supreme Court; Reported Cases: Oak Industries, Inc. v. Commissioner, 96 T.C. 559 (1991), and Libbey v. Commissioner, 55 T.C.M. (CCH) 1052 (1988); Author: "Squaring the Transfer Pricing Circle," 33 Tax Mgmt. Intl. J. 3 (2004), "Control, Causality and Section 482," 28 Tax Mgmt. Intl. J. 403 (1999), .
Steven C. Wrappe
Steven C. Wrappe, Esq., New York University School of Law, LL.M. (Taxation) (1988); University of Texas School of Law, J.D. (1985); University of Notre Dame, Bachelor of Business Administration (1980). Member, State Bar of Texas; Certified Public Accountant. Partner, National Transfer Pricing Team, Deloitte & Touche LLP, Washington, D.C. Formerly, IRS APA Program attorney. Internationally–recognized speaker on the resolution of transfer pricing disputes, with speeches before the Tax Executives Institute, American Bar Association, and Federal Bar Association. Adjunct faculty member at George Mason University Law School, teaching International Tax, and guest lecturer in the LL.M. Program at New York University School of Law. 
Dong Jun Yeo
Dong Jun Yeo, Tax Attorney, Kim & Chang; Seoul National University, College of Social Science, International Economics (B.A., 1980); University of Illinois, Urbana-Champaign (M.A. in Accounting, 1987); Employment, Tax practice in Korea (1981-1985), tax practice, New York (1987-1992); Member, Korean Institute of Certified Public Accountants, American Institute of Certified Public Accountants. Languages: Korean and English.