Speakers

Fabian Alfonso, BaseFirma Inc.
Mr. Alfonso is a partner for BaseFirma’s International Transfer Pricing Group in Miami, Florida.  Mr. Alfonso has 15 years of experience in transfer pricing policy and implementing, documenting, and defending cross-border transactions for multinational companies. He has been involved with numerous transfer pricing projects for companies operating in various industries, including insurance, energy, personal goods, and telecommunications industries, among others. In addition, Mr. Alfonso specializes in managing multi-country transfer pricing projects for multinationals located throughout the Americas.  Mr. Alfonso is a frequent speaker at international transfer pricing seminars and contributor to international tax publications, such as International Tax Review – U.K. and the Bureau of National Affairs of Washington.  Mr. Alfonso has a Business Administration degree with an emphasis in Finance from Universidad de los Andes in Bogota and a graduate degree in International Tax Law from Universidad Externado de Colombia. He is Fluent in Spanish and English. 

Barbara Angus, Chief Tax Counsel, House Ways & Means Committee
Barbara M. Angus serves as Chief Tax Counsel for the Committee on Ways and Means of the United States House of Representatives.  She was appointed to this role by Chairman Brady in February 2016. Prior to joining the staff of the Ways and Means Committee, Barbara was a Principal with Ernst & Young LLP and a member of the National Tax Department.  Based in Washington, D.C., she led EY’s Strategic International Tax Policy Services practice. Barbara previously served as the International Tax Counsel for the Office of Tax Policy, United States Department of the Treasury, from 2001 to 2005. In that position, she was the federal government's principal legal advisor on all aspects of international tax policy, including development of legislation, promulgation of regulations and administrative guidance, and negotiation of tax treaties.  She also represented the United States in the Organisation for Economic Co-operation and Development as a Vice Chair of the Committee on Fiscal Affairs.  From 1995 to 1998, Barbara was the Business Tax Counsel for the Congressional Joint Committee on Taxation, with primary responsibility for all international aspects of tax legislation and analysis of tax treaties considered by the Senate. Barbara also has extensive private sector experience, including forming and operating a consulting firm that developed legislative and regulatory solutions for multinational clients across the spectrum of tax issues. She was a national partner in the federal tax policy group at PricewaterhouseCoopers and was a partner with Kirkland & Ellis in Chicago. Barbara was included in the list of ten Outstanding Women in Tax published by Tax Analysts.  She has been an adjunct professor in the tax L.L.M. programs at Georgetown University Law Center, DePaul University College of Law, and Chicago-Kent College of Law.  She also was a founding member of an all-lawyer comedy troupe in Chicago. Barbara received an A.B. (mathematics and economics), magna cum laude and Phi Beta Kappa, from Dartmouth College. She received a J.D., cum laude, from Harvard Law School.  She received an M.B.A. (finance and accounting), with high honors, from the University of Chicago Graduate School of Business.

Brad Anwyll, Steptoe & Johnson
Brad Anwyll represents clients in tax controversy and litigation matters involving federal and international issues, with a particular focus on transfer pricing and other cross-border disputes. A seasoned tax litigator with 35 years of experience, Mr. Anwyll has litigated more than 30 cases before the US Tax Court, the US Court of Federal Claims, federal district courts, and US Courts of Appeals.  He has also represented clients in more than 150 cases before the IRS’s Advance Pricing and Mutual Agreement Program, and more than 100 matters before the IRS’s Examination Division and Appeals Office.  Mr. Anwyll’s representations have involved advance pricing agreements, competent authority proceedings, transfer pricing, R&D credits, informal refund claims, and structured transactions, among other issues. Before joining Steptoe, he was a principal at PricewaterhouseCoopers.

Clark Armitage, Caplin & Drysdale
J. Clark Armitage, an experienced lawyer in the transfer pricing sector, joined Caplin & Drysdale as a Member in 2013.  Mr. Armitage's core practice is advising multinational corporations on transfer pricing in all contexts, from planning to cross-border dispute resolution.  He has a particularly strong background interacting with tax authorities on advance pricing agreements (APAs) and Competent Authority matters for corporations in a wide range of industries. Mr. Armitage spent eight years in the IRS Advance Pricing Agreement Program, serving as Deputy Director from 2008 to 2010, where he both experienced and oversaw the full spectrum of Program activities.  He also served a special detail as the Tax Treaty Manager responsible for Canadian Competent Authority cases.

Sherif Assef, KPMG
Sherif Assef over 20 years of transfer pricing experience. He joined KPMG LLP in 2016 as a Principal in Washington National Tax, and is based in New York. He has been named one of the world's leading transfer pricing professionals by Legal Media Group and has extensive experience advising clients on a variety of transfer pricing matters, particularly with respect to financial services and transactions. Prior to joining KPMG, Sherif was with Duff & Phelps and Ceteris.


Alejandro Barran, Servicio de Administracion Tributaria (SAT), Mexico
Alejandro Barran is a Director at the Mexican Tax Administration office in charge of the analysis and negotiations of Transfer Pricing APA’s and MAP’s, for non-oil & gas taxpayers, where he has also being part of Mexico’s Delegation at the OECD’s WP6 and FTA MAP Forum. Alejandro got a degree in actuarial science from the Autonomous University of Mexico, and started his career in the TP field about 10 years ago in the consulting services industry. 

Kara Boatman, KPMG
Kara leads KPMG’s transfer pricing practice in the Bay Area. She has a Ph.D. in Economics and more than 20 years of experience in transfer pricing and valuation. Kara has served clients in a variety of industries, including technology, pharmaceutical, biotechnology, manufacturing, transportation, and consumer products companies. She specializes in intangible property valuation and migration, value chain analysis, transfer pricing planning and global documentation studies.

Michael Bowes, EY
Michael is a Partner and the Technology Industry Leader for the Americas transfer pricing practice. He has 17 years of experience consulting on transfer pricing and tax issues for several of the world’s largest technology companies. His practice focuses on providing valuation and economic consulting services associated with mergers and acquisitions, international tax planning, and the restructuring and reorganization of international operations. He has negotiated U.S. and foreign Advanced Pricing Agreements, managed U.S. and foreign transfer pricing audits, and met with various Competent Authorities on behalf of his clients. Michael is formally based in the firm’s San Jose office, but he serves clients nationally. Prior to joining Ernst & Young, Michael was an Economist with another Big 4 firm, an Economist with Christensen Associates, and a Graduate Teaching Fellow at the University of Oregon in the Economics Department. 

Oscar Burakoff, Deloitte
Oscar Burakoff is a Principal in Deloitte’s Transfer Pricing practice, based in San Diego. He focuses his practice on transfer pricing and valuation and has experience managing global transfer pricing projects covering all types of transactions, including cost sharing, transfers of tangible and intangible property, intercompany services, and financing.  Some of Mr. Burakoff’s specific areas of focus include intangible property valuation and planning, cost sharing, supply chain optimization and restructuring, and services allocation analyses. Mr. Burakoff has substantial experience serving companies in the consumer products industry in all of these areas. Mr. Burakoff speaks at a number of professional seminars and has been recognized twice by Legal Media Group as one of Transfer Pricing’s “Rising Stars.” Mr. Burakoff co-authored “Supply chain planning in the post-BEPS era: five questions for MNEs,” International Tax Review, March 2015; Lexology, July 2015. Prior to joining Deloitte, Mr. Burakoff was a Principal Economist at DLA Piper.


Mark Bronson, Duff & Phelps
Mark Bronson joined Duff & Phelps in 2012. A managing director in the Boston office, Mark has significant experience addressing transfer pricing issues for multinational companies and government agencies. He has helped numerous clients resolve disputes through audit, appeals, competent authority and APA venues. Mark has a wide variety of industry experience, with a particular focus on pharmaceutical, biomedical device, and other technology-driven industries. Prior to joining Duff & Phelps, Mark was a Managing Director with Ceteris, as well as a Vice President at one of the largest international economic consulting firms. Mark’s background also includes two years serving in the Advanced Pricing Agreement ("APA") program of the US Treasury, where he was the lead economist for the cost-sharing industry specialty group; there he served on a small team of individuals from the IRS and treasury that were working to resolve valuation issues in the proposed cost-sharing regulations. In addition to cost-sharing experience, Mark has a deep background addressing complex intangible and tangible transfer pricing issues in tax planning, compliance, and controversy resolution contexts.Mark holds an MBA with accounting and finance concentrations from the University of Chicago Booth School of Business. He also has a BA from the University of Rochester in economics and statistics.

Richard Bruch, Horst Frisch
Richard Bruch is a Managing Director of Horst Frisch Incorporated, an independent economic consulting firm based in Washington, DC.  In over 20 years at Horst Frisch, he has provided transfer pricing guidance to U.S. and foreign-based multinational companies and to the IRS to assist with tax planning, documentation, controversy, and Advance Pricing Agreements.

Nate Carden, Skadden
Nate Carden is Partner, International Tax & Tax Controversy with Skadden, Arps, Slate, Meagher & Flom LLP and focuses on both planning and controversies arising in connection with transfer pricing and related international tax issues. Building on several years of experience as a management consultant with McKinsey & Co. and serving as a law clerk for The Honorable Diane P. Wood of the United States Court of Appeals for the Seventh Circuit, Mr. Carden specifically concentrates on the tax aspects of ongoing business operations. He works with corporate and other clients across many industries, with a particular focus on life science, health care and technology companies. Mr. Carden’s transfer pricing and operational planning practice focuses on planning and pre-audit issues arising from cross-border intangible property, service and financing transactions. He also has provided advice and related documentation concerning cross-border transactions and applying U.S. and Organisation for Economic Co-operation and Development (OECD) transfer pricing rules. Mr. Carden’s dispute resolution practice emphasizes the representation of corporate taxpayers in pre-audit, audit, administrative appeal and litigation proceedings. He focuses on resolving substantive tax disputes and addressing discovery and evidentiary privilege issues arising from financial audits, IRS examination and litigation. Mr. Carden has been recognized as a leading lawyer in Chambers USA: America’s Leading Lawyers for Business and in International Tax Review’s issue on tax controversy lawyers. He also has received repeated mentions in the International Tax Review’s World Tax publications. Mr. Carden received his B.A. from Georgetown University and his J.D. from University of Chicago Law School.

Clark Chandler, Economics Partners
Dr. Chandler has assisted taxpayers with transfer pricing issues at audit and appeals in the United States and other countries, as well as by providing expert testimony in Tax Court. He has also prepared numerous studies that have been used in Advanced Pricing Agreements (APAs) and in Competent Authority negotiations. During the course of his career, Dr. Chandler has worked with the U.S. Internal Revenue Service as well as various other tax authorities on transfer pricing controversy matters. In the areas of planning and compliance, Dr. Chandler has worked on intangible migration, licensing and cost sharing projects, providing assistance with initial design, implementation and operation, documentation and defense. Dr. Chandler has experience in a diverse range of industries, including high technology, pharmaceutical and biologics, medical devices, energy, food and beverage, diversified industrials and consumer products. Dr. Chandler has been actively involved in providing comments to the OECD with respect to its transfer pricing guidance, and has participated in numerous discussions and trainings of tax authorities with respect to their local implementation of transfer pricing rules. Prior to joining Economics Partners, Dr. Chandler was a lead technical advisor with respect to transfer pricing at KPMG’s Washington National Tax Practice and in support of its Global Transfer Pricing Services. Prior to that, Dr. Chandler was Vice President at Economic Consulting Services Inc., leading its transfer pricing practice.

Kenneth Christman, EY
Kenneth P. Christman Jr. is a member of Ernst & Young LLP's International Tax Services practice. He is also a member of the National Tax Department and is based in Washington, DC, where he works in the Transfer Pricing practice. Ken advises large multinational clients on transfer pricing controversy, planning and structuring, with a particular emphasis on cross-border transfers of intellectual property, the provision of financial services and cost sharing arrangements. He also represents clients under audit by tax authorities and before the Internal Revenue Service (IRS) Appeals function. Prior to joining Ernst & Young LLP in February 2010, Ken was an attorney with the IRS in Branch 6 (the transfer pricing branch) of the International Division. Ken received his Bachelor of Arts, magna cum laude, Phi Beta Kappa, from Princeton University; his Juris Doctor from Yale Law School; and a Master of Laws in Taxation from New York University School of Law.

Tony Coughlan, Senate Finance Committee
Tony Coughlan joined the Republican staff of the Senate Finance Committee in January 2009, where he works on corporate, international, and various individual tax issues.  Senator Orrin Hatch of Utah has been the leader of the Republicans on the Committee since early 2011, and has been chairman since early 2015.   For the three years prior to joining the Committee staff, Tony was a tax director for Oracle Corporation in California.  And from 1998 to 2006, he worked for PricewaterhouseCoopers, in both the Washington National Tax Service, as well as the Hong Kong office.  From 1996 to 2002, he served three terms as an elected member of the Fairfax City Council in the Virginia suburbs of Washington, DC where he took a lead role in successfully sponsoring real property tax reform legislation, authorizing Fairfax City to tax improvements at a lower rate than land. This bipartisan legislation was signed into law by then-Governor Mark Warner. Tony did not seek re-election in 2002 so as to focus on career and family.  Tony is a graduate of Virginia Tech (double major in Math and History), the University of Virginia School of Law, and of the Georgetown University Law Center LLM tax program, with distinction.‎ His articles on stock options, real estate taxation, and the R&D Tax Credit have appeared in The Tax Lawyer, the George Mason Law Review, and Tax Notes.

Michael Cragg, Brattle Group
Dr. Michael Cragg is Chief Operating Officer and a member of the firm’s Management Committee and Compensation Committee. He has extensive experience in research, teaching, and consulting and has been an expert witness in finance, antitrust and complex damages matters. Dr. Cragg has assisted numerous corporations, the U.S. Department of Justice, and the IRS in developing economic and financial testimony in complex financial litigation. He has recently testified about CDS contracts in the Ambac bankruptcy, about structured finance deals in the failure of AIG, about various financing activities in the Lehman bankruptcy and in several matters involving the financing and investment activities of various banks, leasing companies, mutual funds, hedge funds, venture capital funds and insurance companies. Dr. Cragg also leads case teams in complex litigation in the financial sector. For instance, he led the case team for the Department of Justice in its litigation against the former partners of Long Term Capital Management. More recently, he led a team that included Noble Prize Winner Dr. Joseph Stiglitz involving the failure of the Irish banking sector and the legality of various activities undertaken by the Irish government. Dr. Cragg also has assisted corporations, the U.S. Department of Justice, and the FTC in various antitrust and intellectual property matters. He developed the litigation plan for ten separate experts in various Microsoft litigations. He assisted the FTC in the Mylan pharmaceutical matter which resulted in the largest antitrust settlement ever. He has been involved in several investigations of changes in market structure before and after deregulation in the U.K. and through the California Energy Crisis. He also developed testimony in various MasterCard/Visa antitrust litigations. In addition, Dr. Cragg has been involved in numerous disputes involving the pharmaceutical industry, medical device, services and high tech industries where he has valued intangible property, determined royalty rates and analyzed antitrust damages. Most recently, Dr. Cragg was a testifying expert on market power and the importance of O’Hare’s expansion in the dispute brought by United and American Airlines against the City of Chicago. Prior to joining The Brattle Group, Dr. Cragg was a founding member of Cambridge Finance Partners, the founding partner for the Boston office of Bates White & Ballentine, and vice president at Analysis Group. Dr. Cragg has served as a management consultant at CFP, A.T. Kearney, and Integral. Dr. Cragg began his career as a professor at Columbia University and UCLA's Anderson School of Management, where he taught courses in public finance, industrial organization, and econometrics. He has served on the faculty of the World Bank Training Programs, was an economist at RAND, and a senior research economist at the Milken Institute in Santa Monica, CA. Dr. Cragg was President of the Board of Trustees of the Cambridge Montessori School, a pre-K through grade nine school of 250 students.

Rod Donnelly, Morgan, Lewis & Bockius
Rod Donnelly focuses his practice on the tax aspects of complex international corporate transactions. Representing large multinational corporations, his experience includes transfer pricing, especially with an intangible property component, at both the planning and controversy stages. Rod’s experience also includes Subpart F and foreign tax credits, as well as tax-related aspects of manufacturing supply chain and R&D, at both the planning and controversy levels.

Lorraine Eden, Texas A&M University
Lorraine Eden is Professor of Management and Gina and Anthony Bahr Professor in Business at Texas A&M University, where she teaches courses on transfer pricing, multinational enterprises (MNEs) and international business. Her Transfer Pricing Aggies program, launched in 2007, has trained more than 275 graduate students, with nearly 100 now employed in transfer pricing.  Dr. Eden is President Elect and a Fellow of the Academy of International Business (AIB) where she received the 2012 President’s Award for contributions to the field of international business. Women in the Academy of International Business (WAIB), which she founded in 2001, gave her its inaugural Woman of the Year award in 2016. She is a former editor-in-chief of the Journal of International Business Studies, the top-ranked journal in the field of international business studies. Her 160+ scholarly publications have received almost 10,000 citations. Among her books are Taxing Multinationals: Transfer Pricing and Corporate Income Taxation in North America (1998), Multinationals in North America (1994), Retrospectives on Public Finance (1991), and Multinationals and Transfer Pricing (1985, reissued in 2017). Dr. Eden’s current research on MNEs focuses on high-tech strategic alliances and MNE strategies in "hot spots." She is also writing a book on the economics of transfer pricing and preparing an edited collection of transfer pricing readings. She has more than 25 years of consulting experience with the private and public sectors, including testimony before the Canadian House of Commons and UNCTAD, and teaching transfer pricing courses for the Canada Revenue Agency and the U.S. Bureau of Labor Statistics. She consults on transfer pricing and MNE strategies with the Analysis Group, where she was recently an expert witness on the appropriateness of using transfer pricing to allocate the bankruptcy proceeds of a high-tech MNE. 

Rocco Femia, Miller & Chevalier
Rocco Femia is a member at Miller & Chevalier Chartered. His practice focuses on international tax planning for domestic and foreign-based enterprises, and on assisting such enterprises in avoiding or resolving controversies with the Internal Revenue Service (IRS) and foreign tax authorities involving U.S. international tax rules, transfer pricing, and U.S. tax treaties. Mr. Femia has represented taxpayers before the IRS, the U.S. Department of the Treasury, the Joint Committee on Taxation, and the staffs of the House Ways and Means Committee and the Senate Finance Committee. Mr. Femia has also advised governments on U.S. international tax developments. Mr. Femia is a former Associate International Tax Counsel at the U.S. Department of the Treasury, Office of Tax Policy. While at the Treasury, Mr. Femia had responsibility for a broad spectrum of U.S. tax treaty and international tax regulatory and legislative matters. Mr. Femia was the principal staff attorney involved in the negotiation of the 2003 U.S.-Japan tax treaty and had responsibility for regulatory and other guidance in the areas of intercompany transfer pricing, Subpart F, and entity classification (check-the-box). He advised senior officials on pending legislation regarding U.S. international taxation, including the 2003 Jobs and Growth Revenue Reconciliation Act and the 2004 American Jobs Creation Act. Mr. Femia also represented the interests of the United States in international organizations, including the Organisation for Economic Co-operation and Development (OECD) Committee on Fiscal Affairs.

Susan Fickling-Munge, Duff & Phelps
Susan Fickling-Munge is a managing director in the Chicago office of Duff & Phelps. She is a member of the Transfer Pricing practice, leveraging more than 15 years of transfer pricing and valuation experience. Susan has worked closely with global companies in a vast range of industries, assisting them with transfer pricing planning, documentation and defense.  Susan has extensive experience in international and multistate tax planning projects, employing various transfer pricing techniques to help support her clients’ tax strategies. She has also assisted clients on unilateral advance pricing agreements. She has helped to develop real options models and valuation techniques to support complex transfer pricing and tax structuring scenarios. Before joining Duff & Phelps, Susan was a vice president of transfer pricing for Charles River Associates, a transfer pricing manager in the international tax division of Arthur Andersen LLP and a transfer pricing consultant at KPMG LLP. Susan earned her MBA at the University of Chicago Booth School of Business and her BA from Scripps College. She also studied at the Universidad San Francisco de Quito in Quito, Ecuador, and is fluent in Spanish.

Steve Heubeck, IRS





John Hickey, Johnson & Johnson
John is a Director Transfer Pricing and Tax Planning for Johnson & Johnson.  John’s current responsibilities include all cross border related party transactions, international tax planning, ASC740 reserve analysis, oversight of transfer pricing documentation and audit defense (both financial and tax authorities) for cross border transactions (services, tangible and intangible property).    John has developed, implemented and defended multiple pricing models, including profit splits for intangibles and routine returns for low risk functions and services. John has broad tax experience in public and corporate tax including various roles focused on supply chain planning.  John has a Masters in Taxation from Villanova School of Law and Bachelor of Business Administration from Temple University.

Rob Kovacev, Steptoe & Johnson
Rob Kovacev combines his skills in civil litigation with substantive knowledge of the tax laws to represent taxpayers in high-profile, high-stakes tax disputes against the Internal Revenue Service (IRS), both at the administrative level and in Tax Court and federal district and bankruptcy courts.  Mr. Kovacev’s practice focuses on anticipating and defending against IRS challenges to cross-border transactions involving transfer pricing issues, disputes over the research tax credit and the Section 199 domestic production activities deduction, and disputes involving the economic substance doctrine and related judicial doctrines.  Mr. Kovacev is an experienced trial lawyer with extensive first-chair experience who has been called into civil tax cases on the eve of trial as lead trial counsel. In addition to his active tax controversy and litigation practice, Mr. Kovacev also advises taxpayers how to anticipate, address, and overcome potential IRS challenges to transactions before controversies begin.  In particular, Mr. Kovacev provides advice regarding the research tax credit, the Section 199 domestic production activities deduction, and intellectual property-related tax issues. Prior to joining the firm, Mr. Kovacev was a senior litigation counsel in the United States Department of Justice, Tax Division, responsible for litigating some of the largest and most complex civil tax cases in the nation.  In that position, Mr. Kovacev worked closely with the IRS’s Large Business & International (LB&I) Division and top management of the Tax Division to shape litigation strategy on high-priority tax enforcement issues. 

Russell Kwiat, IRS
Russell Kwiat is a Senior Manager within the IRS’s Advance Pricing and Mutual Agreement Program (APMA).   Since joining the IRS, Mr. Kwiat has functioned in various roles, including working on and negotiating advance pricing agreements and mutual agreements, participating in regulations committees for cost sharing and 367(d), assisting in litigation matters, advising examination teams on complex audits, playing an instrumental role in knowledge sharing initiatives, and serving as a Country Manager.  Prior to joining the IRS, Mr. Kwiat worked for a Big Four accounting firm in the area of transfer pricing.  Mr. Kwiat has degrees in economics and finance from The Wharton School of the University of Pennsylvania and The Robert H. Smith School of Business at the University of Maryland.  

Michael Lennard, UN

Pat Lewis, Caplin & Drysdale
Ms. Lewis' practice currently focuses on international transfer pricing issues, competent authority matters, and other aspects of international taxation. This includes tax planning advice on compliance with U.S. and foreign transfer pricing rules in connection with ongoing business operations or business transactions, as well as assistance in the event of tax audits and other administrative controversies. A particular emphasis is the negotiation of advance pricing agreements (APAs) between taxpayers, the IRS, and foreign tax authorities. Highlights Ms. Lewis represents businesses in many industries, including financial services. She has worked with major U.S.-based multinationals as well as U.S. affiliates of foreign corporations, involving cross-border transactions with Japan, the United Kingdom, France, India, Canada, Brazil, Sweden and Germany, among others. Ms. Lewis was particularly active in the fight to protect the confidentiality of APAs from unwarranted disclosure. Ms. Lewis has fundamental knowledge of French.  

Carlos Mallo, EY
Carlos Manuel Mallo is a member of Ernst & Young LLP’s Transfer Pricing practice in Washington, DC. Carlos practices in the area of tax controversy, with a particular emphasis on valuation of intellectual property (IP) and Advanced Pricing Agreement and Competent Authority negotiations. Carlos’ professional experience includes assisting clients from a wide variety of industries with IRS audits, implementation of cost-sharing agreements and valuation of IP. Carlos received a BS in Economics from the Universidad de la Republica (Uruguay) and a PhD in Economics from Boston University. He is a certified Enrolled Agent.

Sam Maruca, Covington
Sam Maruca has practiced exclusively in the area of federal income tax since 1983, focusing in recent years on large-case controversies, including complex transfer pricing disputes. He has represented both U.S. and foreign-based multinational companies in the biopharmaceutical, information technology, internet commerce, communications and media, consulting services, heavy manufacturing, and retail sectors, in matters at the audit level, in IRS Appeals, in mediation, in competent authority, and in the courts. His expertise includes the preparation of opinion letters and compliance advice relating to cross-border financing transactions and transfer pricing matters; interpretation of tax treaties; treatment of controlled foreign corporations under subpart F; taxation of inbound transactions; and the applicability of penalty regimes. In advising clients, he often collaborates with foreign legal advisers and works regularly with leading transfer pricing economists and industry experts.

Donna McComber, Baker McKenzie
Donna McComber is a director of economics for Baker McKenzie Consulting LLC in Washington, DC. She is a seasoned transfer pricing advisor with deep technical insight into complex transfer pricing issues. Prior to rejoining Baker McKenzie, Ms. McComber was assistant director of the Advance Pricing and Mutual Agreement Program (APMA) under the US Internal Revenue Service's Large Business & International Division. She managed teams that were responsible for cases in the following countries: Argentina, Caribbean countries, China, Denmark, Eastern European countries, Germany, India, Ireland, Israel, Mexico, Portugal, Norway, Spain, Sweden, Switzerland, UK and Venezuela. Prior to becoming assistant director, she was the deputy director (technical) and reviewed US positions and negotiated APA MAP cases with treaty partners including Australia, Canada, China, Denmark, Germany, Japan, Mexico, Korea, Switzerland, and the UK. Prior to the IRS, Ms. McComber was a senior economist with Baker McKenzie.

Michael McDonald, U.S. Department of the Treasury
Michael McDonald is a financial economist in the Business and International Tax Division of Treasury’s Office of Tax Analysis since 2001.  Michael represents the United States at Working Party 6 (Taxation of Multinational Enterprises) of the OECD’s Committee on Fiscal Affairs, as well as on a number of WP6 and WP1 (OECD Model Tax Treaty) subsidiary groups. He was Chair of WP6 for the BEPS work on transfer pricing (Action Items 8-10).  He is a member of the United Nations subcommittee that drafted the United Nations Practical Manual on Transfer Pricing for Developing Countries, and is a delegate to the OECD’s Tax and Development Task Force.  He has participated in a number of bilateral income tax treaty negotiations.  Prior to joining the Treasury Department, Michael was a transfer pricing economist in the National Tax Department at Ernst & Young (1996-2001).  Prior to working at E&Y, Michael was on the Revenue Estimating Division at Treasury’s Office of Tax Analysis (1988-1996). Michael received a Ph.D. in economics from Boston College in 1988.

Tom Meyer, Horst Frisch
Tom Meyer joined Horst Frisch as an Analyst in 1992 and, after completing his M.B.A., rejoined the firm as an Associate in 1997. He became a Director in 2004 and a Managing Director in 2006. During his many years at the firm, Mr. Meyer has provided expert analysis to a variety of U.S. and foreign-based multinational companies and to the IRS. He has advised clients on a range of transfer pricing issues involving tax planning, documentation, audits, and Advance Pricing Agreements. Mr. Meyer's areas of expertise include the valuation of tangible and intangible assets, financial statement analysis, and transfer pricing accounting issues. Prior to joining Horst Frisch, he was a Legislative Correspondent for a United States Senator where he worked on tax, business, and agricultural issues. Mr. Meyer holds an M.B.A. from the University of Michigan Graduate School of Business and a B.A. in Economics and Mathematics from the University of Vermont. He also holds a Chartered Financial Analyst certification.

Bill Morgan, Horst Frisch
Bill Morgan is a Managing Director of Horst Frisch Incorporated, an independent economic consulting firm based in Washington, DC.  In over 20 years at Horst Frisch, he has performed work across many industries and provided expert advice on a diverse set of transfer pricing cases.  Prior to rejoining Horst Frisch in 2015, Mr. Morgan served for over three years as the Chief Economist and adviser to the Director of Transfer Pricing Operations (TPO) in the Large Business & International division of the Internal Revenue Service.  He has published articles on timely transfer pricing issues, been a guest speaker at various industry conferences, and testified before the U.S. Congress House Committee on Ways & Means as an expert on transfer pricing matters.

Russ O'Haver, Northwestern University
Russ O’Haver, PhD in Economics, is a clinical professor in the business school at Northeastern University.  Prior to that, Russ start and led – for over 15 years – Ernst & Young’s New York based Transfer Pricing practice.  In that capacity, Russ built one of the largest global Transfer Pricing practices -- of over 100 professionals in the Northeast -- and worked in all phases of transfer pricing, though specializing in Intellectual Property strategies and controversy defense (including APAs, audits, appeals, and litigation).  Most of Russ’s clients clustered in the High Tech, branded Consumer Products and Media and Entertainment industries. He is a frequent speaker and writer in the field.

Mike Patton, DLA Piper
Mike Patton is a partner in DLA Piper's Tax practice, based in Los Angeles. He focuses his practice on international transfer pricing. Mr. Patton 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. He was instrumental in obtaining the world’s first Advance Pricing Agreement, and he has assisted clients in negotiating more than 100 APAs. Mr. Patton was previously an attorney in the IRS Chief Counsel's Office where he had national responsibility at IRS for technical issues, regulations and litigation of cases relating to transfer pricing. Mr. Patton was editor of and a major contributor to the Treasury/IRS Transfer Pricing White Paper. The White Paper laid the theoretical ground work for the profit-based transfer pricing methods adopted by the US and the OECD. Mr. Patton has been named one of the Best of the Best US transfer pricing advisors as well as one of the leading Asia Pacific tax advisors by Euromoney and the Legal Media Group. He is an editorial advisory board member of Tax Management, Inc. and is the author of the BNA portfolio Treatment of Advance Pricing Agreements. 

Philippe Penelle, Deloitte
Philippe Penelle is a Principal with Deloitte Tax, LLP, specializing in designing, valuing, and defending transactions that involve the transfer of certain intellectual property rights (IPR). Philippe brings over 20 years of professional experience as a technical economist, assisting his multinational clients set-up, maintain, document and defend foreign partnership structures, transfers of IPR through cost sharing arrangements, through contributions to corporations under IRC 367, and through licensing arrangements involving specific allocations of fixed cost funding commitments. In addition to his client work in Life sciences, Technology, Entertainment and Media Industry, Fashion and Retail Industry among others, Philippe has published a number of highly technical original articles developing valuation methodologies relevant to these IPR structures and consistent with the IRC and the Treasury regulations promulgated thereunder. These articles have been published in BNA Transfer Pricing Report, International Tax Review, Global Tax Weekly, and Bloomberg BNA Tax Management Memorandum. Philippe is a frequent invited speaker at external conferences and has been recognized by Euromoney (Legal Media Group) as one of the world’s leading transfer pricing advisers.

Stefanie Perrella, Duff & Phelps
As a leader in Duff & Phelps’ New York Transfer Pricing Practice, Stefanie provides global transfer pricing advice to organizations that range from Fortune 500 companies to start-up businesses. Specifically, she has over eight years of experience assisting these clients with all aspects of transfer pricing from planning, documentation, and implementation to controversy and advanced pricing agreements.Stefanie is also a thought leader on Duff & Phelps' Financial Services Transfer Pricing team, spending a significant amount of time focused on transfer pricing strategy for financial services clients as well as establishing best practices for assessing intercompany debt and other intercompany financing arrangements for clients across a wide spectrum of industries. Stefanie also has significant experience providing transfer pricing valuation services associated with cost sharing arrangements and intangible transfers to clients primarily in the pharmaceutical and medical device space. Early in her career Stefanie co-lead two high-profile litigation engagements on behalf of taxpayers under audit by the IRS. Stefanie began her career in transfer pricing at NERA Economic Consulting, and prior to joining Duff & Phelps, was an Associate Director for Ceteris. Stefanie received a B.S. degree (summa cum laude) in International Affairs with a concentration in Finance and a M.A. degree in International Economic Relations from American University. Stefanie has co-authored a number of articles for publications, such as Bloomberg BNAI and Thomson Reuter’s Practical International Tax Strategies, and is an award winning speaker that has also presented on transfer pricing topics at international conferences. 

Tim Reichert, Economics Partners
Dr. Reichert’s experience in the fields of applied economics, transfer pricing, and valuation is both broad and deep. Tim brings nearly 20 years of experience in applied economic consulting, and has practiced in a wide range of areas, including transfer pricing, complex valuation, lost profits and lost benefits (economic damages) analysis, and intangible asset pricing and valuation. His practice focuses on tax controversy and planning that depends upon intercompany transfer pricing. Dr. Reichert is frequently called upon to provide assistance as an expert witness, and to resolve large transfer pricing or valuation-related controversies. In this capacity, Dr. Reichert has been retained by tax authorities as well as corporate taxpayers, and he maintains good relationships with tax authorities around the world. Dr. Reichert is also a well-known author and speaker. Dr. Reichert has substantial experience in the following industries: agriculture, automotive, banking, biotech, chemicals, cement, computer products, consumer durables, consumer non-durables, distribution, branded food and beverage, greeting cards, healthcare, insurance, mining, oil and gas, pharmaceutical, pharmaceutical distribution, primary metals, primary metal inputs, servers and storage, software, semiconductor, wine and spirits, and others. Prior to founding Economics Partners, Dr. Reichert was a Managing Director and the global service line leader for transfer pricing and economics at Duff & Phelps, LLC. Prior to that Dr. Reichert was a Partner with Ernst & Young, LLP.

Jesse Rosenthal, Discovery
As the global TP leader for Discovery, Jesse is responsible for all transfer pricing matters, including planning, implementation, documentation and audit support.  He also works closely with business leaders on business model design and optimization.  Jesse has over 12 years’ experience in transfer pricing.  Prior to joining Discovery in 2013, Jesse was based in Hong Kong where he managed the Asia transfer pricing function for a leading food and beverages MNC.  Jesse has a bachelor degree in international business and a masters degree in finance and currently resides in Washington, DC. 

Judd Schneider, Duff & Phelps
Based in the Boston office, Judd joined Duff & Phelps in conjunction with the merger of Standard & Poor’s Corporate Value Consulting (CVC) with Duff & Phelps. He has over 12 years of experience valuing business enterprises, legal entities, debt and equity securities, intangible assets, intellectual property and derivative instruments for purposes of financial and tax reporting, M&A planning, tax reorganizations and restructurings. Judd’s extensive experience includes analyzing and valuing intangible assets of industrial, consumer products and technology companies pre- and post-transaction in accordance with ASC 805 (formerly SFAS 141R); net assets and invested capital of companies’ reporting units in connection with impairment testing pursuant to ASC 350 (formerly SFAS 142); legal entities for internal tax reorganizations and other tax planning; equity securities for gift and estate tax and business planning purposes; complex preferred equity instruments; and preparing debt capacity analyses. Judd received his B.S. in finance and economics from the University of Florida. He is also a Chartered Financial Analyst Charterholder and a member of the Boston Security Analysts Society. In his spare time, Judd co-founded StopLeukemia.org, a non-profit organization designed to provide personalized support to individuals, families and friends impacted by leukemia.

Kartikeya Singh, PwC
Kartikeya Singh is a Principal in PwC's Transfer Pricing group and is based in their Washington Metro office. Since joining PwC in 2006, Kartikeya has specialized in the economic analysis of intercompany arrangements and the economic valuation of tangible property, intangible property and services. Kartikeya's experience has covered most facets of transfer pricing including compliance and documentation, tax controversy and litigation, advance pricing agreements, and competent authority matters.  He has worked with clients in the consumer packaged goods, pharmaceuticals, biotechnology, medical products, online retail, and high-tech industries.  Prior to joining PwC's transfer pricing practice, Kartikeya has held positions at the Corporate Executive Board, International Monetary Fund, and at the University of Maryland where he taught undergraduate courses in economics.  

Erik Skarstad, Disney
Erik Skarstad is The Walt Disney Company's Vice President of Transfer Pricing and is based in the United States. In this capacity, Erik leads transfer pricing strategy for the company (e.g., IP and royalty planning, supply chain, policy determination, business restructurings), advises on transfer pricing operations, uses transfer pricing documentation to mitigate risk, and works globally to manage transfer pricing controversy for Disney. Prior to joining Disney, Erik managed NIKE's global transfer pricing for almost eight years and was a Managing Director in the Global Transfer Pricing Services practice at KPMG where he advised multinational companies in the technology, telecom, financial services, and healthcare industries. Early in his career, Erik worked in strategy consulting and investment banking. Over the course of his career in transfer pricing, Erik has actively contributed to the tax, transfer pricing and valuation communities by publishing in industry journals, speaking at conferences, leading advance pricing agreement (APA) negotiations, and resolving transfer pricing disputes.  Erik holds an MBA in Economics and Finance from Columbia University and a BA in Economics from Carleton College.

Sanford Stark, Morgan, Lewis & Bockius
Sanford W. Stark focuses on federal tax controversy and litigation. He counsels on a range of complex domestic and international issues, including a substantial emphasis on transfer pricing. Sanford advises clients in various industries and on all aspects of the controversy process, including pre-audit, audit, appeals, Advance Pricing Agreements and Competent Authority (now APMA), and the federal trial and appellate courts. Sanford’s transfer pricing experience includes significant focus on identifying and valuing intangible property, and further includes transfer pricing planning and internal restructurings. Sanford is a member of the Bloomberg BNA Transfer Pricing Advisory Board, and he teaches “Introduction to Transfer Pricing” as an adjunct professor in the Graduate Tax Program of Georgetown University Law Center. Sanford is the co-author of "Transfer Pricing: Litigation Strategy and Tactics", BNA Tax Management Portfolio, 893 T.M. (2010). Additionally, Sanford frequently speaks on transfer pricing, tax controversy, and litigation topics. He is a member of the American College of Tax Counsel. Describing him as a “great practitioner whom peers and clients all trust and respect,” and noting his “transfer pricing expertise,” Chambers USA has named Sanford one of the country’s leading tax controversy lawyers since 2007. Clients say he “takes the time to understand us and you really feel he is part of your team. He always does what’s right for the client.” Sanford has also been recognized as a key controversy and transfer pricing partner by Legal 500. While serving as a trial attorney in the Tax Division of the US Department of Justice, Sanford litigated many tax issues in the federal courts and received the Tax Division’s Outstanding Attorney Award. Previously, he clerked for Judge Peter Hill Beer, US District Court, Eastern District of Louisiana.

Elizabeth Stevens, Caplin & Drysdale
Elizabeth Stevens joined Caplin & Drysdale in 2015 as an Associate after her clerkship with Judge Robert A. Wherry, Jr., of  the U.S. Tax Court.  Ms. Stevens' combined experience in government, private practice, and the nonprofit sector gives her a 360-degree perspective on federal income tax and corporate issues, as well as valuable insights that benefit the firm's corporate and individual clients.  Ms. Stevens' practice centers on international tax planning and advocacy for corporate clients.  Matters involve transfer pricing, U.S. inbound investment taxation, and counseling on the tax implications of multinational groups' transactions and entity structures.  Illustrations of Ms. Stevens' legal services include: advising corporate clients on transfer pricing planning, documentation, and compliance, including negotiating Advance Pricing Agreements; representing clients in LBO transactions and assisting with the drafting and negotiation of partnership and LLC operating agreements; guiding clients seeking Competent Authority assistance under bi-national Double Taxation Avoidance Agreements and counseling on other treaty-related matters, such as the creation and taxation of permanent establishments; evaluating and advising on the tax consequences of multinational enterprises’ restructuring proposals; and representing clients in tax litigation matters and providing strategic guidance in pre-litigation controversies.

Bartley Tablante, Keystone Strategy

Bartley is an Engagement Manager for Keystone Strategy located in their Boston office.  Here, he leads the economic consulting work on behalf of several global brands whose industries include technology, consumer goods, and telecommunications.  His work includes project management and research, analysis for Keystone’s economic experts, and economist training for the firm’s Economics Team.  Bartley received both his M.A. and Ph.D. in Economics from the University of Michigan, where his studies focused on microeconomic theory with an emphasis on environments of incomplete information.  He also holds a B.A. in Economics and Computer Science from Williams College.  Bartley was a graduate student instructor at the University of Michigan where he taught an array of economic courses.

Joe Tobin, Deloitte
Joe Tobin is a Senior Manager in Global Transfer Pricing at Deloitte's Washington National Tax Practice. Joe is a world-renowned expert in transfer pricing controversy and transfer pricing planning, especially in the area of cost sharing arrangements. Joe serves a wide variety of clients, specializing in intangible-centric industries such as the high-technology industry and the bio-pharmaceutical industry. Joe was the primary drafter of the US Treas. Reg. §1.482-7 (2011) Final Cost Sharing Regulations and the US Treas. Reg. §1.482-7 (2013) Final Cost Sharing Regulations. Joe was chosen by USCIB to comment on the OECD's 2015 Discussion Draft on Cost Contribution Arrangements. Joe also helped the ABA and USCIB draft comments on Notice 2015-54 and the Section 367 temporary regulations and Section 482 temporary regulations released in September 2015. Joe was previously Senior Counsel at the I.R.S. Office of Associate Chief Counsel (International) (Branch 6) (Transfer Pricing) in Washington D.C., where he was a reviewer for several high profile transfer pricing litigation cases, including VERITAS, Medtronic, Amazon, and BMC Software. Joe also advised I.R.S. Exam and Field Counsel on hundreds of contentious transfer pricing audits that went to I.R.S. Appeals. Joe was also commented on several versions of the draft I.R.S. Appeals Settlement Guidelines on Cost Sharing Buy-Ins, which have never been published. Joe was also known as the "go to" person for Advanced Pricing Agreements (APAs) with complex technical issues involving cost sharing arrangements (CSAs), and he advised on several such APAs with CSAs. Joe has spoken at numerous conferences, webcasts, and training sessions on transfer pricing and cost sharing. He has been a member of the Georgetown Law Adjunct Faculty since 2013, where he co-teaches a class on transfer pricing. Joe received a Masters Degree in Tax Law from New York University in 2007, a JD from the University of Virginia in 2005, and a Bachelor of Arts in Philosophy and Political Science from Reed College in 1995. Joe is licensed to practice law in Nevada and New York. Joe served in the US Army from 1997 to 2005 and was deployed several times, including deployments to Bosnia-Herzegovina and Cuba.

Perry Urken, Economics Partners
Perry Urken is Partner at Economics Partners, LLC, and has provided economic consulting services in the fields of transfer pricing and tax valuation for nearly 15 years. His practice focuses on the provision of transfer pricing and tax planning services to multinational firms and assistance in tax controversies.  In this context, Mr. Urken has performed a wide variety of economic analyses, including enterprise valuation, intangible asset valuation, and various transfer pricing analyses. Mr. Urken’s transfer pricing practice focuses on the pricing of intercompany transfers and licensing of intellectual property.  In this context, he assists clients with intercompany sales of intellectual property portfolios, cost sharing arrangements, business restructurings, and intercompany licensing arrangements.  Mr. Urken has extensive experience designing and structuring the terms of these types of transactions as well as defending these terms as part of audits, advance pricing agreements, and other proceedings with tax authorities.  Mr. Urken has substantial experience in a wide variety of industries, including private equity, consumer products, building materials, apparel, automotive, pharmaceutical, commodities, and semiconductors.  Mr. Urken frequently makes presentations on issues relating to transfer pricing and valuation at conferences and seminars and also publishes frequently on these topics. In August 2012, Mr. Urken opened Economics Partners’ Washington DC office, which now includes a full complement of experienced transfer pricing professionals.  Prior to joining Economics Partners, Mr. Urken was a Vice President in the Transfer Pricing practice of Charles River Associates, where he was responsible for transfer pricing and tax valuation in its Washington DC office.  Previously, Mr. Urken was a Senior Manager with the Ballentine Barbera Group and, prior to that, a Manager with KPMG LLP.

Brian Vincent, Economics Partners
Mr. Vincent’s practice focuses on the provision of international transfer pricing, audit/controversy defense and tax-efficient supply chain planning services. Mr. Vincent has experience in assisting clients with advance pricing agreement negotiations, business restructurings and post-acquisition transfer pricing integration and harmonization efforts. In this context, Mr. Vincent has developed models and authored reports involving complex profit splitting analyses, intangible asset valuations, restructured supply chains and acquisition due diligence efforts related to transfer pricing matters. In addition to his planning and controversy services, Mr. Vincent assists clients in identifying and evaluating transfer pricing risks and uncertainties in the context of computing interim and annual tax provisions and for purposes of complying with both FIN 48/ASC 740-10 and the IRS Schedule of Uncertain Tax Positions. Mr. Vincent has performed applied economic consulting services for clients in a wide array of industries, including private equity and asset management, pharmaceuticals, automotives, industrial components, consumer products, apparel, aerospace and oil and gas exploration and production. Prior to joining Economics Partners, Mr. Vincent was a Principal in the Transfer Pricing practice of Charles River Associates, where he assisted clients with transfer pricing and tax valuation issues. Previously, Mr. Vincent held transfer pricing and valuation consulting roles with The Ballentine Barbera Group and KPMG LLP.

Jill Weise, Duff & Phelps
Jill Weise joined Duff & Phelps in 2012 as a managing director leveraging more than 20 years of transfer pricing expertise. Jill is currently the North American Leader of the firm’s Transfer Pricing Practice. Throughout her career, she has worked with global clients to address an array of transfer pricing issues – including planning analyses, global studies, advance pricing agreements, controversy, litigation (including expert witness testimony), state transfer pricing, cost sharing, intangible asset migration, tax reserve calculations, and documentation for penalty protection. Jill has extensive industry experience in such areas as high-tech, computer software, biotechnology, medical instrumentation, pharmaceuticals, industrial products, chemicals, food and beverage, retail, and automotive. Prior to joining Duff & Phelps, Jill was the leader of Ceteris’ Boston practice and was integral to building the practice to the success it is today. Prior to joining Ceteris, Jill was the Director of Deloitte’s New England transfer pricing practice and the east coast transfer pricing leader at Charles River Associates. Jill is on the Board of Directors for the National Association of Business Economists and currently the Co-Chair of this organization’s transfer pricing roundtable. She also serves on the International Fiscal Association’s New England Chapter Advisory Council. She frequently speaks at external events sponsored by law firms, professional associations and educational organizations. In addition, Jill has published articles in academic and trade journals – including Journal of Political Economy, BNA TP Report, Tax Management Memorandum, Euromoney and World Finance. She has been interviewed and featured by several publications, including the International Tax Review and Tax Business. Jill has been listed in Euromoney’s (Legal Media Group) "Guide to the World’s Leading Transfer Pricing Advisers" and named as one of the top Woman Tax Leaders –Transfer Pricing in International Tax Review’s Women Tax Leaders publication. Jill has an MA in Economics from The University of Chicago, along with a BA in Mathematics and a BA in Economics from Bates College.

Robert Weissler, IRS
Mr. Weissler is a Senior Advisor in the Internal Revenue Service's Advance Pricing and Mutual Agreement (APMA) Program.  Previously, Mr. Weissler served in APMA's predecessor program, the Advance Pricing Agreement Program in the Office of the Associate Chief Counsel (International), which he joined in 1996.  He has contributed to the economic and legal theory of transfer pricing, including drafting the APA Study Guide and working on the cost sharing regulation project.  He has also contributed to procedural matters such as the recent IRS Revenue Procedures for advance pricing agreements and competent authority assistance.  Before joining the IRS, Mr. Weissler helped to develop early computer networking technology, analyzed technology-related policy for Congress, and practiced law in the areas of intellectual property, international trade, and general litigation.

Ken Wood, IRS

Iñigo Zapater, IRS

Tom Zollo, KPMG
Tom is a principal in the International Corporate Tax Group of KPMG’s Washington National Tax practice. Tom focuses on structuring the operations of multinational corporations, primarily in the industrial and consumer market sectors. Tom has led a number of international supply chain redesign projects for U.S.-based multinationals involving the establishment of regional entrepreneur companies. He also has significant experience advising non-U.S. multinationals on issues related to the establishment and operation of their U.S. businesses, including the application of treaty provisions, the U.S. effectively connected income rules, and the U.S. interest-stripping rules. Tom has considerable experience in tax controversy matters, particularly those involving transfer pricing. He has represented taxpayers before IRS Appeals throughout the US, in the US Tax Court, and in competent authority proceedings. Tom served as the United States reporter on business restructurings to the 2011 International Fiscal Association World Congress and has spoken at many of the world's leading tax forums. He is recognized in both Euromoney’s Guide to the World’s Leading Tax Advisors and Guide to the World’s Leading Transfer Pricing Advisors.