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.

Lisa M. Starczewski, Esq., Co-Chair; Counsel, Buchanan, Ingersoll & Rooney; J.D., Villanova University School of Law, summa cum laude; B.A., Smith College, magna cum laude.  Lisa Marie Starczewski is Counsel in the tax department at Buchanan, Ingersoll & Rooney. She served as Editor-in-Chief of the Villanova Law Review (1987–88) and has practiced tax law with Morgan, Lewis & Bockius and Schnader, Harrison, Segal & Lewis. She has also taught in the LL.M program at Villanova University School of Law. Ms. Starczewski has authored more than 20 Bloomberg BNA Tax Management Portfolios in both the U.S. Income and Accounting series. She is also the author and co-author of numerous Bloomberg BNA Tax Practice Series chapters. She has received the Tax Management Distinguished Author Award and is co-chair of the following Bloomberg BNA Tax Management Advisory Boards:  U.S. Income; Corporate Tax; Real Estate; Estates, Gifts & Trusts; Compensation Planning; U.S. International; and Transfer Pricing.

Akira Akamatsu, Esq., White & Case LLP.  Tax attorney Akira Akamatsu counsels both national and international clients on tax examinations, litigation, advance pricing arrangements and competent authority consultations under tax treaties. He is additionally noted for his scholarly contributions as both a lecturer and author.  Dr. Akira Akamatsu 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.

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. Nat Boidman is a partner in the Taxation practice of Davies Ward Phillips & Vineberg LLP. He specializes in international taxation, with a focus on advising on cross-border mergers and acquisitions, financings and other business arrangements and relationships, including joint ventures, partnerships and business trusts. Nat also provides counsel on disputes with Canada Revenue Agency stemming from cross-border tax matters, including transfer pricing and advises on individual international tax issues, including personal investment and migration matters.

Herman B. Bouma J.D., University of Texas at Austin School of Law (1979) with honors; B.A., Philosophy and Mathematics, Calvin College, (1972); Buchanan Ingersoll & Rooney PC, Washington, DC.  Senior Tax Counsel at Buchanan Ingersoll & Rooney, PC, Herman B. Bouma has over 35 years of experience in the area of U.S. taxation of income earned in international operations. Over his career, his work has fallen into four general areas: legislative, regulatory, transactional, and audit and litigation.  Herm has assisted major U.S. firms and financial institutions with tax planning and analysis, advising on such matters as the structuring of multibillion-dollar international financial transactions, the creditability of foreign taxes, Subpart F, transfer pricing, foreign acquisitions, reorganizations, and restructurings, and compliance with reporting requirements. He has met on behalf of clients with members and staff of the House Ways and Means Committee, the Senate Finance Committee, and the Joint Committee on Taxation, and with the Assistant Secretary of the Treasury (Tax Policy), the International Tax Counsel, and the IRS Associate Chief Counsel (International). Herm was an advisor to the taxpayer in Exxon Corporation v. Commissioner, 113 T.C. 338 (1999) (creditability of the U.K. Petroleum Revenue Tax under sections 901/903), and to the taxpayer in The Coca-Cola Company v. Commissioner, 106 T.C. 1 (1996) (computation of combined taxable income for a possession product under section 936).

Clark J. Chandler, Principal, KPMG LLP; Dickinson College, B.A. (1974); University of Michigan, M.A. and Ph.D., Economics (1978). Clark J. Chandler, Ph.D., Principal, Economic & Valuation Services, at KPMG LLP focuses primarily on the areas of transfer pricing and the valuation of intangibles for large firms. In his more than 25 years of transfer pricing controversy work, Chandler has extensive experience with international transfer pricing issues involving tangible and intangible property, as well as services and cost sharing arrangements.  Clark provides national support to KPMG’s Economic & Valuation Services (EVS) practice in the area of transfer pricing and the valuation of intellectual property, and is the lead technical advisor with respect to transfer pricing issues for Global Transfer Pricing Services (GTPS). In this role, he is responsible for preparing GTPS’s regular technical memoranda and advanced transfer pricing training, and plays a key role in the review and development of technical content for GTPS's major international conferences.

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, Esq., Partner, Asia Pacific Transfer Pricing Leader -  International Tax Services, Ernst & Young Solutions LLP; M.B.A., University of Southern California; B.S., International Trade and Customs, Universidad Iberoamericana, honors.  Luis Coronado is a partner based in Ernst & Young's member firm in Singapore and is the Far East Area and Greater China transfer pricing leader. Luis will be returning to Shanghai in January 2010.  Luis has worked in Asia since 2005 as part of his more than 15 years advisory experience in international tax and transfer pricing issues.

William G. Dodge, Principal, Deloitte Touche Tohmatsu; University of Georgia, Master of Accountancy (tax) (1979); Walsh College, B.A. (1976). William G. Dodge serves as Director, Global Transfer Pricing Team and Co-Director, U.S. Transfer Pricing Team at Deloitte & Touche LLP, Washington, DC. Mr. Dodge was Partner-in-Charge, U.S. Corporate Tax Group at Deloitte & Touche, London, England. He also worked in New York, London, and Tokyo, where he served many of Deloitte & Touche's largest U.S. and non-U.S. clients. He serves as a Member of Transfer Pricing Advisory Board at Tax Management, Inc. Mr. Dodge is a Member of the Tax Management Advisory Board (Transfer Pricing). He is a regular Speaker at seminars.

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, Esq., Principal, PricewaterhouseCoopers; J.D., Boston College; M.B.A., Boston University; B.S., Boston University.  Mr. 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.

Carlo Galli, Esq., Partner, Clifford Chance; LL.D., Università Statale, Milan (2012); Qualified as a Dottore Commercialista (chartered accountant) (1996); Degree in Business Administration, Università Bocconi (1992).  Carlo Galli is a Partner and Head of the Tax practice of Clifford Chance in Milan, Italy where he is part of the global Tax group handling tax issues related to capital markets and structured finance, M&A, tax planning and transfer pricing. Carlo regularly advises domestic and international clients on all aspects of tax in complex transactions and has significant experience in the structuring and financing of inbound and outbound investments. He specializes in the following sectors: Consumer goods & retail, healthcare, life sciences & chemicals, industrials, private equity, real estate, telecom, and media & technology.

Samir Gandhi, Esq., Partner, Deloitte Haskins & Sells; Bachelor of Commence, University of Mumbai.  Samir Gandhi, with over 20 years of experience in the fields of direct tax and transfer pricing, heads up Deloitte's transfer pricing group in India. He is also present at and holds regular discussions with the Expert Group on Transfer Pricing/Policy Makers formed by the Government of India. Mr. Gandhi has been recognized as a leading transfer pricing advisor in India by the Euromoney Legal Media Group and World Tax 2009, and his articles have been published in the BNA Transfer Pricing Report, the International Tax Review, the Japan Taxation Journal, and leading Indian financial dailies.

Brian S. Gleicher, Esq., White & Case LLP; B.S., University of Florida, Fischer School of Accounting, with high honors, 1992; J.D., Georgetown University Law Center, cum laude, 1995. A Partner with White & Case, Brian Gleicher focuses on international tax issues with an emphasis on transfer pricing and tax treaty issues. He routinely represents multinational companies in transfer pricing matters, including advance pricing agreements, with the Internal Revenue Service and foreign tax authorities. He also advises taxpayers on proceedings before the US and foreign Competent Authorities on a broad range of issues, including double taxation, residency and permanent establishment questions. 

Bruno Gouthiere, Esq., CMS Bureau Francis Lefebvre; Master in Law, the University of Paris, graduated from the Institute of Political Science of Paris and the Ecole Nationale d'Administration; BS., Economics, the University of Paris. Bruno Gouthière has been a partner with CMS Bureau Francis Lefebvre, international tax department, since 1989. Previously, he was 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”, “The International Guide to Holding Companies” (IBFD, co-editor), co-author of various books on “Wealth” (Memento du Patrimoine), “Civil Companies” (Memento Sociétés Civiles), Groups of Companies (Memento Groupes), etc., and of numerous articles in French and foreign legal, tax, and financial reviews. He is notably a member of the Transfer Pricing Advisory Board of the Tax Management International Journaland a member of various associations of tax practitioners such as the International Fiscal Association (“IFA”). He is Vice President of the European Fiscal Confederation (“CFE”).

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

Steven P. Hannes, McDermott Will & Emery LLP; Amherst College, B.A. (1967); J.D., New York University School of Law (1970); B.A., Amherst College (1967). Steven Hannes is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's Washington, D.C., office.  Mr. Hannes has been recognized in the Legal 500; named “Best of the Best” tax advisors for transfer pricing in surveys by Euromoney; listed in Woodward/White's The Best Lawyers in America in the specialty of Tax Law and Litigation and Controversy-Tax Law, recognized in The International Who’s Who of Corporate Tax Lawyers and The International Who's Who of Business Lawyers; and U.S. News has included Mr. Hannes in its best list for the Tax Law category.

Marc M. Levey, Esq., Baker & McKenzie LLP; J.D., University of Cincinnati College of Law (1972); LL.M., University of Miami Law School (1973); B.S., Wilkes University (1969).  Marc Levey is a partner in the New York office of Baker & McKenzie. He has over 35 years of experience in international taxation and is nationally recognized in his field, particularly in structuring and defending transfer pricing strategies. He has frequently been acknowledged by Euromoney as one of the “World’s Leading Tax Advisors,” included in its “Best of the Best” global tax experts. Mr. Levey serves as the co-chair of the Firm’s Luxury & Fashion Industry Group and a member of the US Transfer Pricing Management Team. He was the past chair of the Firm’s Global Transfer Pricing Steering Committee.

Samuel M. Maruca, Esq., Covington & Burling LLP, Washington, D.C.

Dennis I. Meyer, Esq., Baker & McKenzie LLP; B.S., University of Dayton (1957); Georgetown University (J.D., 1960; LL.M., 1962). Dennis Meyer is a member of the Baker & McKenzie’s North American Tax practice group. Prior to joining Baker & McKenzie, Mr. Meyer served as Attorney Advisor to the Chief Judge of the United States Tax Court. Mr. Meyer has been an adjunct professor of international tax law at the Georgetown University Law School, as well as a lecturer on international taxation at other national universities.

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

Michael F. Patton, Esq., DLA Piper LLP; University of Maryland (B.A. and J.D. with honors, Order of the Coif), Georgetown University Law Center (LL.M., Taxation). A Partner with DLA Piper, Mike Patton focuses his practice on international transfer pricing.  Mike has assisted many multinational corporations in a variety of industries in resolving IRS or foreign tax authority transfer pricing and other tax disputes, as well as in planning major cross-border transactions.  Mike was instrumental in obtaining the world’s first Advance Pricing Agreement (APA) and he has assisted clients in negotiating more than 100 APAs. He has also been active in resolving disputes for clients in Examination, Appeals and Competent Authority procedures.

Irving H. Plotkin, PricewaterhouseCoopers LLP; Ph.D., Massachusetts Institute of Technology; B.S., Wharton School, University of Pennsylvania.  Dr. Plotkin, who works out of PricewaterhouseCoopers' Boston office, is Managing Director of its National Tax Service and Global Dispute Resolution practices; previously, for many years, 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, and taxation on industry efficiency and risk-taking. 

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.