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Transfer Pricing Answer Book (2015 Edition)

Author(s): David B. Blair
Practice Area: Corporate law, Corporate tax, International law, International tax, Tax
Date: Jun 2015 i Other versions can be found in the Related Items tab.
ISBN: 9781402424786
PLI Item #: 142972
The phenomena of increasingly global business enterprises with valuable intangible property expose companies to transfer pricing enforcement by different countries around the world.  Many of these countries are increasingly aggressive in enforcing their local transfer pricing rules, as they attempt to protect their tax revenue base.  To avoid double taxation of the same income in this environment, companies often are required to deal with the highly specialized, bilateral treaty-based competent authority process developed to prevent double taxation at a time when trade mainly involved only two established countries.  Even more challenging today, companies and tax authorities increasingly are faced with the potential for multiple taxation of the same income, as supply chains cross many borders and as the tax authorities of emerging countries become players in the global taxation process, and the resulting stresses, strains, and limitations of the bilateral treaty-based competent authority process have become more apparent.
In light of the high-dollar risks presented by the increased enforcement efforts of tax authorities worldwide, the complexity of the ever-changing, inherently uncertain transfer pricing standards, and the continually evolving business models of businesses adapting to the constantly changing global economy, companies need practical guidance to permit them to develop and defend their transfer pricing strategies. 
Transfer Pricing Answer Book 2015 gives companies such guidance by discussing all aspects of transfer pricing, from initially planning a transfer pricing strategy, to alternative ways to defend the strategy from attack by two or more tax authorities, to resolving a case before competent authorities, to bringing a transfer pricing case to court.  The book’s non-technical discussion is presented in a question and answer format that will appeal to readers regardless of their prior level of experience or familiarity with taxes in general and transfer pricing in particular. 
Transfer Pricing Answer Book 2015 is an invaluable resource for company executives and their advisors who are seeking to better understand this important area of tax law that has become such an important economic facet of so many businesses.

David B. Blair is a partner in Crowell & Moring's Tax Group. Mr. Blair's practice is in the area of federal tax litigation and controversy. With over twenty years of tax litigation and trial experience, he has handled large tax litigations in the areas of transfer pricing, foreign tax credits, partnerships, tax-exempt bonds, consolidated returns, excise taxes, employment taxes, and tax accounting issues. He is also active in pro bono litigation. Where clients sought resolution short of litigation, Mr. Blair achieved outstanding results through alternative dispute resolution procedures, including the Internal Revenue Service's (IRS) Fast Track Settlement program. He also has extensive experience in handling tax controversies before IRS Exam, Appeals, National Office, and Advance Pricing and Mutual Agreement program (APMA).

Mr. Blair is an active member and former Chair of the Tax Section of the Federal Bar Association.  He is a member of the ABA Section of Taxation, and a Fellow of the American Bar Foundation.  From 2005 to 2007, Mr. Blair served as an Adjunct Professor of tax at the Georgetown University Law Center.  He frequently speaks on a variety of tax issues and is active in the J. Edgar Murdoch Inns of Court hosted by the United States Tax Court.  Mr. Blair is ranked by The Legal 500 (2007-2011).  Prior to joining Crowell & Moring, Mr. Blair was a Trial Attorney with the United States Department of Justice, Tax Division (1990-1995).  He also served as a Law Clerk for the Hon. Frank M. Johnson, Jr. of the United States Court of Appeals for the Eleventh Circuit.  Mr. Blair received his law degree in 1989 from Cornell Law School (magna cum laude) and his undergraduate degree in 1985 from Georgetown University.