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Transfer Pricing Advisory Board

BNA's Transfer Pricing Advisory Board is comprised of esteemed professionals from renowned corporations, universities, and government entities. Below is a listing of our current board members.

Leonard Silverstein
Leonard L. Silverstein is the founder of Silverstein and Mullens, which later became part of Buchanan Ingersoll & Rooney PC. He concentrates his practice in estate planning, nonprofit organizations, charitable contributions and representation before the Internal Revenue Service and Treasury Department.

Leonard serves as founder of the highly regarded Tax Management publication series. For the past 50 years, Tax Management has produced and maintained more than 500 portfolios, monthly journals and periodicals, providing tax professionals and advisors with a sophisticated analysis, application and interpretation of the Internal Revenue Code.

Before he founded his own firm with Richard A. Mullens in 1960, Leonard served as an attorney in the Office of Chief Counsel for the Internal Revenue Service and on the legal advisory staff of the Treasury Department. His long history of professional and community service includes roles on the Advisory Group of the House Ways and Means Committee in the late 1950s, as executive director of the "Filer" Commission on Private Philanthropy and Public Needs, as a member of President-elect Nixon's Task Force on Taxes, President Reagan's Committee on the Arts and Humanities and as a member of the IRS Commissioner's (Lawrence Gibbs) Exempt Organizations Advisory Group.

Richard S. Marshall Esq., is a Senior Tax Counsel with the Washington, D.C. office of Buchanan Ingersoll & Rooney PC. Mr. Marshall focuses his practice on corporate and general business tax planning matters at the federal and state levels and represents clients in civil and criminal tax matters before the Internal Revenue Service. Mr. Marshall also serves as the Executive Director of the Bloomberg BNA Tax Advisory Boards, the Deputy Technical Director of the U.S. Income Portfolios and coordinator of the "Washington Items" feature of the Tax Management Memorandum. He is a graduate of Tufts University (B.A.), and the George Washington University (J.D. and LL.M.).

Akira Akamatsu, Esq., White & Case LLP, Tokyo, Japan.

Reuven S. Avi-Yonah, B.A., Hebrew University, 1983; Ph.D., Harvard University, 1986; J.D., Harvard Law School, 1989. Mr. Avi-Yonah is a Professor of Law at the University of Michigan Law School where he teaches domestic and international taxation. He 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).

Nathan Boidman, B. Com., McGill University 1962; B.C.L., LL.B., McGill University 1980. Mr. Boidman is the International Tax Partner at Davies Ward Phillips & Vineberg LLP in Montreal, Quebec. He is a member of Bar of Quebec (and CA, Ontario, and FCA, Quebec) and was on the Executive Committee of the International Fiscal Association (IFA) 1998–2004. Boidman was past president and member of council for the Canadian IFA Branch, past governor of the Canadian Tax Foundation, Joint Committee of Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants. He lectures and writes regularly on international tax matters and is author and originator/co-editor of "Canada-U.S. Tax Practice," Tax Management International Journal, and originator/coordinator of "International Mergers & Acquisitions: A Forum For Discussion," Tax Notes International (Tax Analysts).

Herman B. Bouma is Counsel with the Washington, D.C. office of Buchanan Ingersoll & Rooney PC. Mr. Bouma has over 30 years of experience in the area of U.S. taxation of income earned in international operations, assisting major U.S. companies and financial institutions with tax planning and analysis and advising on such matters as the structuring of billion-dollar international financial transactions, the creditability of foreign taxes, Subpart F issues, transfer pricing, and foreign acquisitions, reorganizations, and restructurings. Mr. Bouma was counsel to the taxpayer in Exxon Corporation v. Comr., 113 T.C. 338 (1999) (creditability of the U.K. Petroleum Revenue Tax under §§901/903), and in The Coca-Cola Company v. Comr., 106 T.C. 1 (1996) (computation of combined taxable income for a possession product under §936). Mr. Bouma began his legal career as an attorney-advisor in the IRS Office of Chief Counsel, Legislation and Regulations Division (International Branch), in Washington, D.C. He was a principal author of the final foreign tax credit regulations under §§901/903, and participated in income tax treaty negotiations with Sweden, Denmark, and the Netherlands Antilles. Mr. Bouma is a graduate of Calvin College and the University of Texas at Austin School of Law.

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.

Grant M. Clowery, C.A. (Canada); CPA (Illinois); Ph.D., Business, University of Chicago; J.D., George Mason University. Dr. Clowery, currently with Clowery Consulting, Washington, DC., has served as an expert witness and counselor for both the Internal Revenue Service and taxpayers on issues relating to transfer pricing, valuation, and financial accounting practice.

Luis Coronado, Ernst & Young (China) Advisory Services Limited, Shanghai, China.

William G. Dodge, University of Georgia, Master of Accountancy (tax) (1979); Walsh College, B.A. (1976). Mr. Dodge is Director, Global Transfer Pricing team; Deloitte Touche Tohmatsu, Sydney, Austrailia. He was formerly Partner-in-Charge, U.S. Corporate Tax Group, Deloitte & Touche, London, England. Mr. Dodge is a member of the Tax Management Advisory Board (Transfer Pricing). He is a 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.

Stephen M. Edge, Esq., is a corporate tax partner at Slaughter and May, where he has an extensive tax consultancy practice that 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 capitalization area.

David Ernick is a Principal in the Transfer Pricing Practice of PricewaterhouseCoopers’ (PwC) Washington National Tax Services office.
 
Prior to joining PwC, David was Associate International Tax Counsel at the U.S. Treasury Department. While at Treasury from 2004-2013, his responsibilities included negotiating tax treaties and trade agreements, drafting regulatory guidance, and advising on legislative matters. He also represented the United States as a delegate to the Organization for Economic Cooperation and Development (OECD) Working Party No. 6 on Transfer Pricing, and served as the Chair of its Special Session on Business Restructurings. David was the principal staff attorney for transfer pricing matters at Treasury, and advised on every significant guidance project in this area released by Treasury and the OECD during his tenure.

Prior to joining Treasury, David practiced as a tax associate at Cravath, Swaine & Moore in New York and at Wilmer, Cutler & Pickering in Washington. He has clerked at the U.S. Tax Court and the U.S. Court of Appeals for the Eleventh Circuit. He currently serves as an adjunct professor and teaches a course on transfer pricing in the Graduate Tax Program at Georgetown University Law Center. He is also a co-author of the 2013 Practising Law Institute's (PLI) Transfer Pricing Answer Book.

Brian S. Gleicher, B.S., University of Florida, Fischer School of Accounting, with high honors, 1992; J.D., Georgetown University Law Center, cum laude, 1995. Mr. Gleicher is a tax partner at White & Case LLP in Washington, DC. He specializes in international tax matters, with an emphasis on transfer pricing and tax treaty matters, as well as domestic tax controversy. Mr. Gleicher is a frequent speaker and author on these topics.

Bruno Gouthiere, graduate of the Ecole Nationale d´Administration, the University of Paris, Master in Law and BS in Economics, and the Institut d'Etudes Politiques of Paris. Mr. Gouthiere has been a 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.  He is the 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 author of numerous articles in French and foreign legal, tax, and financial reviews.  He is notably a member of various associations of tax practitioners such as the International Fiscal Association (IFA) and the Fiscal Committee of the European Fiscal Confederation (CFE).

Dr. Michael E. Granfield, Ceteris, Inc., Dallas, Texas.

Steven P. Hannes, Amherst College, B.A. (1967); New York University School of Law, J.D. (1970). Mr. Hannes was formerly Associate International Tax Counsel for the Department of the Treasury; Group Chief, Corporation Tax Branch, Internal Revenue Service. He is a member of the National Council and Vice President (Washington Region) of the International Fiscal Association. He is a member of the District of Columbia Bar Association, American Bar Association, and Tax Committee of National Foreign Trade Council.

Marc M. Levey, Esq., Partner, Baker & McKenzie LLP, New York, NY.

Dennis I. Meyer, University of Dayton (B.S., 1957); Georgetown University (J.D., 1960; LL.M., 1962). He was Attorney Advisor to Hon. Norman O. Tietjens, Chief Judge of the United States Tax Court. Mr. Meyer is Chairman of the American Bar Association Section on Taxation Committee on Foreign Activities of United States Taxpayers and Fellow of the American College of Tax Counsel as well as a member of the Advisory Board of the World Trade Institute and Fellow of the American Bar Foundation.

R. Russ O'Haver, Ernst & Young LLP, New York, NY.

Michael F. Patton, University of Maryland (B.A. and J.D. with honors, Order of the Coif), Georgetown University Law Center (LL.M., Taxation). Mr. Patton was editor and a major contributor to the Treasury/IRS Transfer Pricing White Paper and was a member of the Treasury/IRS study group to revise the competent authority function. He worked extensively on the OECD Multilateral Treaty on Mutual Administrative Assistance in Tax Matters and the U.S.-Bermuda Tax Convention and was the lead U.S. Treasury negotiator in many negotiations with foreign governments for tax information exchange agreements under the Caribbean Basin Initiative. Mr. Patton was 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. He has also been named as a “Highly Recommended” tax advisor by the International Tax Review. Patton is a member of the Transfer Pricing Advisory Board of Tax Management Inc. and a contributor to the Tax Management International Journal, the Transfer Pricing Reporter, and other publications. He is a Principal with Ernst & Young, a member of the International Tax Services Group in the National Tax Department.

Dr. 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 DuPont, 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.

Ulises Ruíz, Instituto Tecnológico Autónomo de Mexico (ITAM) Law School in Mexico (1992), Universidad Panamericana (Taxation, 1994; Constitutional Litigation, 1996), New York University (LLM in Tax, 2000). Mr. Ruíz is a member of the International Fiscal Association and a registered litigator before Mexican Federal courts and before the Mexican Court of Fiscal and Administrative Justice. He has worked in the International Division of the Mexican Ministry of Finance (1992–1996), worked with PricewaterhouseCooper’s international tax practice in New York (1997–2004) and is currently Senior Manager with the Latin American Business Center of Ernst & Young LLP in New York, NY.
Craig A. Sharon, Esq., Bingham McCutchen LLP, Washington, D.C.

Dr. Klaus Sieker, Flick Gocke Schaumburg, Frankfurt, Germany.

Sanford W. Stark, Esq., Partner, Bingham McCutchen LLP, Washington, D.C.

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). Mr. Thomas is a Partner at White & Case LLP in Tokyo, Japan. He is admitted in Japan as a licensed tax attorney (zeirishi) and is a member of Tokyo Zeirishi Association, California State Bar Association, and Dai-ni Tokyo Bar Association. Mr. Thomas is also a speaker on Japanese international tax issues and an author of numerous articles on Japanese taxation in the United States, Japan and Europe.

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), .

Rom P. Watson, Esq., Ropes & Gray, Boston, MA.

A. Duane Webber, Kansas State University (B.A., B.S., 1981); Georgetown University (J.D., 1984). Mr. Webber is a member of the Section of Taxation (Court Procedure Committee), Section of Litigation of the American Bar Association, Taxation Section of the Federal Bar Association, and the J. Edgar Murdock American Inn of Court.

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). Mr. Wrappe is a member of the State Bar of Texas and a Certified Public Accountant. He is a Partner with Ernst & Young in Washington, DC. He was formerly an IRS APA Program attorney. Mr. Wrappe is an internationally recognized speaker on the resolution of transfer pricing disputes, with speeches before the Tax Executives Institute, American Bar Association, and Federal Bar Association. He is an adjunct faculty member at George Mason University Law School where he teaches International Tax, and he is a guest lecturer in the LL.M. Program at New York University School of Law.