Aptis Global is a specialised international tax and transfer pricing firm with offices in San Diego, Tijuana and Brussels. Kathrine Kimball is the founder and the managing principal. She has extensive experience in global transfer pricing, value chain analysis, intangible property valuation and supply chain transformation tax planning. The firm encompasses the full cycle of transfer pricing, from planning to compliance to controversy. The team advises multinational companies in different industries.
Baker McKenzie has a strong reputation in transfer pricing. The group offers services in planning, compliance, controversy, APAs. It consists of more than 40 partners, counsels, associates, economists, analysists and other professionals. Salim Rahim is the chair of the firm’s global transfer pricing group. He has extensive experience in transfer pricing matters, including transfer pricing planning, compliance and tax controversy. Overall, the practice involves negotiating and facilitating APAs for US and foreign-based multinational companies in different sectors, including e-commerce, pharmaceutical, manufacturing, automotive and financial services.
Over the research period, the team advised the largest multinational on complex transfer pricing matters.
A full-service Atlanta-based firm, Bennett Thrasher has a solid transfer pricing practice. The group has extensive experience in transfer pricing planning, documentation and compliance. It is active in assisting with the negotiation of advance pricing agreements with the IRS and foreign tax authorities and in defending transfer pricing positions in the US. Ben Miller is the head of the transfer pricing practice.
Over the research period, the group assisted a provider of digital marketing services with pricing related-party services to its US subsidiary. The firm, moreover, in response to the tax reforms has begun providing transfer pricing consulting services.
“Outstanding and exceeded my expectations.”
Crowell & Moring has a robust transfer pricing practice. In particular, the firm excels in tax controversy and litigation in the areas of transfer pricing, foreign tax credit, partnerships, employment taxes and tax accounting issues. Overall, the team represents large companies and corporations in different sectors, including software, telecommunications, healthcare, petroleum, mining, automotive, banking and finance.
David Blair, partner in the Washington DC office, is the practice leader of the tax controversy and transfer pricing areas. Another key contact is David Fischer, a partner in Washington DC, who has extensive transfer pricing experience. Bradford Anwyll is a senior counsel at the firm and has a particular focus on transfer pricing.
Deloitte is among the top players in transfer pricing. Partner John Womack is the US managing partner for international tax, transfer pricing and indirect tax. The large team consists of nearly 1,300 professionals. The group represents companies and helps them to address their tax compliance risks by aligning practical transfer pricing approaches with their overall global business operations.
The firm specialises in business model optimisation, tax structuring, M&A, multistate tax services, cross-border tax and tax compliance.
In terms of lateral moves, the firm strengthened its transfer pricing practice with the addition of Rahul Tomar. He is based in Philadelphia.
Dentons’s tax team is very active in transfer pricing. The group represents multinationals regarding compliance with US transfer pricing rules, including transfer pricing documentation requirements and the production of foreign-based documents. The group is also experienced in resolving transfer pricing disputes and using dispute resolution mechanisms under US income tax treaties.
Epsilon Economics is a Chicago-based firm of economists and financial analysts with global clients, including Apple, Dell, Samsung, Microsoft Nissan, Chase and Bayer. Epsilon’s transfer pricing expertise includes planning, documentation and compliance, dispute resolution and tax valuation.
The team provides advice on developing global transfer pricing policies and procedures, as well as guidance on implementing, setting and monitoring remuneration for intercompany transactions. The team is led by Jill Kosonen. She has an extensive experience in transfer pricing and valuation for multinational enterprises, real estate investment trusts (REITs) and tax-exempt organisations.
“Practical and creative.”
“Epsilon is great to work with. They have a very helpful demeanor. They are very knowledgeable about the transfer pricing of intangibles and good at recommending practical solutions tailored to our practical business needs.”
Fenwick & West’s transfer pricing practice is an important part of its tax dispute resolution practice. They regularly advise many large corporations and work with many of the world’s leading law-firm tax advisers outside of the US, including tax attorneys in China, India, Taiwan, Australia, Netherlands, Canada, Brazil and Mexico.
The firm offers services in areas such as transfer pricing disputes and APAs. It has represented clients with developing transfer pricing policies that reflect the changing tax regimes in many parts of the world.
“Excellent. Knowledgeable and clear advice.”
Mayer Brown’s transfer pricing group is one of the most active in the country. The practice area is a major component of the tax controversy practice in each of the law firm’s Chicago, New York, Washington DC, Houston and Palo Alto offices. Many attorneys are devoted almost exclusively to transfer pricing and internal restructuring matters. They bring an extensive experience in the representation of corporate taxpayers in transfer pricing planning, audits, IRS appeals and litigation.
In the last 12 months, the group handled sophisticated large transfer pricing cases. It advised multinationals in a wide range of industries, including manufacturing, software, oil and gas, pharmaceuticals and financial institutions.
The team at McDermott Will & Emery represents clients in various issues relating to transfer pricing. The group excels in transfer pricing planning, APAs and controversy matters for multinationals across a variety of industries.
In the last 12 months, the group assisted the large retailer of hunting, fishing, camping and outdoor equipment Cabela’s on a variety of matters, including on a tax and transfer pricing dispute with the IRS. Another interesting mandate was the representation of several companies, including Ahold, Exxon Mobil, Hess, Shell, Honeywell, Pfizer and Eli Lilly in different matters. Other key clients included Procter & Gamble.
Miller & Chevalier Chartered’s transfer pricing team is among the top players in the country. The group represents some of the world’s largest companies across different sectors, including oil and gas, automotive, pharmaceutical, electronics, telecommunications, business services and retail. The firm helps to resolve transfer pricing adjustments by tax authorities in the US, Canada, Germany, Mexico, Korea, Japan and India. Layla Asali is the vice chair of the tax department and has extensive experience in transfer pricing.
In the last 12 months, the group worked on impressive transfer pricing cases valued at billions. A standout mandate was to represent the Coca-Cola Company before the US tax court in a high-stakes transfer pricing dispute.
The Morgan Lewis & Bockius transfer pricing group is among the key players in the country. Firm-wide tax practice group leader Bart Bassett and tax partner Rod Donnelly lead the transfer pricing planning and controversy practice on the West Coast. The group advises clients on international tax planning and tax aspects of complex international corporate transactions. Sanford Stark oversees the Washington DC-based tax practice and together with John Magee, leads the transfer pricing controversy and litigation practice. Partner Thomas Linguanti leads the Chicago-based tax practice and is focused on tax controversy and transfer pricing areas.
Over the research period, the group in California assisted Zimmer Biomet in a complex transfer pricing dispute pending before the US tax court. In addition, the group in DC served as lead counsel in two of the biggest transfer pricing cases to go to trial, involving Coca-Cola and Amazon. The Chicago group represented numerous clients, including Perrigo Company and Medtronic. The cases are ongoing.
Skadden Arps Slate Meagher & Flom regularly advises US and international multinationals on a wide range of transfer pricing and other cross-border tax controversy matters in different offices. The law firm focuses on planning, pre-audit issues arising from cross-border intangible property, service and financing transactions.
Most of the transfer pricing cases remain confidential.
Vinson & Elkins is a well-distinguished law firm in transfer pricing. The group has extensive experience with transfer pricing and advises companies on numerous US federal income tax matters. The team serves clients in multiple industries, including airlines, shipping, financial services, real estate, computer software, life sciences, healthcare and oil and gas.
Partners David Cole and George Gerachis are both key contacts at the firm.
The team at White & Case is very active in transfer pricing. They provide a broad range of services in domestic and international dispute resolution, negotiation of APAs, transactional and planning advice. Kim Marie Boylan is the head of its global tax practice. She has extensive experience in transfer pricing. Brian Gleicher is the firm’s head of transfer pricing. He focuses on international tax issues with an emphasis on transfer pricing and tax treaty issues. The team represents multinational companies in transfer pricing matters, including APAs with the IRS and foreign tax authorities.
In the last 12 months, the group worked on numerous high-profile cases. All of them remain confidential.