Gary D. Sprague Esq.

Gary D. Sprague, Esq., B.A., Stanford University (1977, with honors; Phi Beta Kappa); J.D., Harvard Law School (1981, cum laude); Partner, Baker & McKenzie, LLP; Business Co-Chair of OECD Technical Advisory Group on Treaty Characterization Issues arising from E-Commerce; Business Co-Chair of OECD Technical Advisory Group on Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits; co-author, Source of Royalty Income and Place of Use of Intangible Property, Tax Management International Journal (August 2007); co-author, Permanent Establishments and Internet-Enabled Enterprises: The Physical Presence and Contract Concluding Dependent Agent Test, Georgia Law Review (Fall 2003); author, Application of Transfer Pricing Rules to Branches and Permanent Establishments—Electronic Commerce and Intangible Property Aspects, The George Mason Law Review (Summer 2002); co-author, General Report on Main Subject I: Taxation of Income Derived from Electronic Commerce, Cahiers de Droit Fiscal International (2001); co-author, United States Taxation of Income from International Electronic Commerce Transactions, Tax Management Memorandum (December 2000); co-author, The Final Software Revenue Characterization Regulations, Tax Management International Journal (February 1999); co-author, Characterization of Computer Software Revenue in International Transactions, TAXES (December 1996); member of American Bar Association; International Fiscal Association, USA Branch; State Bar of California.