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Transfer Pricing Premier Library

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Description

Transfer Pricing Premier Library provides a comprehensive one-stop source of expert transfer pricing analysis, insights & commentary, news and practitioner-to-practitioner guidance.

Bloomberg BNA’s expert transfer pricing coverage relies on the ongoing input from leading practitioners in the international tax field who are actively engaged in international tax practice for many of the world’s most recognizable global corporations, accounting firms and law firms. They provide ongoing insights into the latest transfer pricing issues and laws, including specific country/jurisdiction concerns and practical applications.

Bloomberg BNA’s Transfer Pricing Premier Library includes four main components:

  • Transfer Pricing International Journal — Obtain the latest analysis to help you minimize taxes and avoid penalties. Transfer Pricing International Journal gives you authoritative commentary and practitioner analysis written by leading Transfer Pricing specialists. Depend on it for the expert guidance you need to prepare a successful transfer pricing strategy.
  • Transfer Pricing Report — practical biweekly service providing news and analysis on 25 governments' tax policies regarding intercompany transfer pricing, permanent establishment and competent authority issues. Transfer Pricing Report helps companies structure their operations to avoid double taxation. It provides analytical news, feature articles and text to keep you up-to-date on the most recent transfer pricing developments around the world. Each update includes the insights of leading practitioners and detailed information on particular issues of practical interest such as the latest on advance pricing agreements.
  • Transfer Pricing Portfolios — 11 Portfolios covering transfer pricing rules of the U.S. and select countries. Written by leading practitioners in this highly complex and constantly evolving practice area, the Transfer Pricing Portfolios provide everything necessary for businesses to manage intercompany prices and avoid penalties as they exchange goods or services between related companies in different countries. In addition to the United States, countries covered include: Australia, Belgium, Brazil, Canada, Denmark, France, Germany, Italy, Korea, Japan, Mexico, the Netherlands, New Zealand, the OECD, Sweden, Switzerland, and the United Kingdom.
  • Transfer Pricing Forum — Transfer Pricing Forum is an online service bringing you detailed practical guidance on technical Transfer Pricing issues. Featuring Transfer Pricing experts from 28 countries, Transfer Pricing Forum provides unique, country-specific solutions to complex technical Transfer Pricing problems. The Forum allows you to compare different approaches to the same transfer pricing problem across jurisdictions.

Transfer Pricing Premier Library helps you:

  • Compare different approaches to the same transfer pricing problem across jurisdictions. Bloomberg BNA’s Transfer Pricing Premier Library is like having an advisory panel of international experts providing solutions to technical transfer pricing issues – without the cost.
  • Recognize and prepare for important technical problems before they arise…and know the right questions to ask when discussing intricate transfer pricing issues with colleagues and clients.
  • Make strategic decisions on cross-border investments…find out how a particular country's handling of transfer pricing can impact your company's cross-border taxation strategies.
  • Save the time it takes to research different transfer pricing applications between different countries… Transfer Pricing Premier Library provides the most comprehensive and in-depth analysis available from any single source.

Product Structure

Portfolios: In-depth analysis of specific topics.

Notification: Current Reports and regular Special Reports providing news and developments.

Source Documents: Primary source material including Laws & Regulations, Agency Documents, and U.S. Tax Treaties.

Formats and Frequency:

Available on the web with ongoing updates.

Authors

Akira Akamatsu
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
Philip Carmichael
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.