Kerwin Chung Esq.

Director, Global Transfer Pricing
Kerwin Chung is a principal in Deloitte Tax's Washington national tax office, and leader of the firm's national advance pricing agreement (APA) and mutual agreement procedure (MAP) group. He has more than 16 years' transfer pricing experience, specialising in APAs, MAP, planning, examinations and customs matters. He has served as the taxpayer's lead negotiator for more than 80 APAs and has represented more than 100 taxpayers in the MAP process. His clients include US- and foreign-based multinationals in numerous industries, including apparel, automotive, chemicals, computers, construction equipment, consumer electronics, electronic components, food and beverage, industrial machinery, insurance, logistics, office products, pharmaceuticals, photography, professional services, and publishing.

Kerwin's practice has involved complex transfer pricing issues, including: negotiating a bilateral APA and rollback for a pharmaceutical company that resulted in the withdrawal of a $100+ million IRS transfer pricing adjustment and penalty assessment; negotiating a bilateral APA and rollback to eliminate double taxation resulting from post-year-end transfer pricing adjustments paid to a US subsidiary that were not deductible in the foreign tax jurisdiction; and negotiating a bilateral APA in conjunction with a customs ruling request to obtain both transfer pricing and customs valuation certainty.

J.D., Harvard Law School cum laude

Bloomberg BNA Tax Management Portfolios:
890 T.M., Transfer Pricing: Alternative Practical Strategies (co-author)