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.