Transfer Pricing 101
LIVE webcast

E. Miller Williams, Jr.
Partner/Principal – National Transfer Pricing
Ernst & Young LLP

E. Miller Williams, Jr. is a Partner/Principal with E&Y’s National Transfer Pricing Group. In this role, Mr. Williams consults with multinational corporate clients on a national basis regarding complex transfer pricing matters with an emphasis on international transfer pricing controversy, advanced pricing agreements (APA), competent authority, and transfer pricing planning and structuring.

Mr. Williams has over 17 years of transfer pricing consulting experience (5 with the government and 12 in private practice) with companies in a variety of industries. His industry experience includes work with paper and pulp, building products, pharmaceutical, semiconductors, software, packaging, retail, consumer products, motor vehicles, automotive parts, heavy equipment, and industrial machinery. Mr. Williams is a frequent speaker at Council for International Tax Education Seminars and other tax seminars and has authored a number of transfer pricing articles.

Prior to joining E&Y, Mr. Williams headed the Southeast transfer pricing practices of a previous Big 5 Firm and of one of the current Big 4 Firms in Atlanta. Prior to private practice, Mr. Williams served as a Senior Attorney in the Office of Associate Chief Counsel (International) for the IRS in Washington D.C. working on a variety of transfer pricing and international tax matters. As a member of that office, he worked in the APA Program where he acted as lead attorney on many APA cases and as advisor to the Director on APA procedures.

Mr. Williams received his LLM in Taxation from Emory University, his J.D. from Stetson University College of Law and his undergraduate degree from Vanderbilt University. Prior to working for the IRS, Mr. Williams served as an officer and attorney in the United States Army Judge Advocate General's Corps where he held positions as a prosecutor, defense attorney and administrative law attorney. He is a member of the Georgia Bar Association and the American Bar Association Tax Section, and is a board member and officer of the Georgia Council for International Visitors and board member of the Atlanta Area Council of the Boy Scouts of America.

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Steven C. Wrappe
Principal, International Tax Services
Ernst & Young LLP

Steven Wrappe is in Ernst & Young LLP’s International Tax Services Transfer Pricing practice and is located in Washington, D.C. He brings over 25 years of tax experience, including over 15 years of extensive focus on all aspects of transfer pricing. Steve’s knowledge in transfer pricing controversy includes: examination, appeals, ADR solutions, advance pricing agreements (APAs), mutual agreement procedures (MAPs), and Customs agreements. His combined APA/MAP experience includes in excess of 100 cases.

Background
Previously, Steve was a partner at a global law firm and, prior to that, spent 10 years as a partner and Director of the APA practice at Deloitte Tax. Steve also brings a wealth of government experience to Ernst & Young, having served as an attorney at the IRS Office of Associate Chief Counsel (International) Advance Pricing Agreement Program.
Steve is actively involved in the international tax and transfer pricing community. He recently served as Chair of the Transfer Pricing Committee of the American Bar Association’s Tax Section. He serves on the Board of Advisors of the NYU School of Law – International Tax Program and BNA Tax Management (Transfer Pricing). Steve is an Adjunct Professor (Transfer Pricing) at Georgetown University Law Center, has published two books and numerous articles on transfer pricing topics, and speaks globally on transfer pricing and dispute resolution.

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Brian Andreoli
Partner
DLA Piper

Brian E. Andreoli focuses his practice on transfer pricing, international tax matters, and state tax matters. Mr. Andreoli has been a tax professional for more than 30 years, with experience in public, accounting, corporate (both foreign and domestic) law, and litigation. He has tried cases and administrative hearings in the states of New York, Connecticut, Ohio, California, Virginia, North Carolina, South Carolina, Pennsylvania and Washington. These cases have concerned corporate income tax, sales and use tax, franchise tax and property tax. He also practices in voluntary disclosures for both corporations and individuals, concerning both civil and criminal penalties.

Mr. Andreoli is admitted before the bars in Connecticut, New York, Massachusetts, and the District of Columbia, and is a Certified Public Accountant. He is licensed to practice in the United States Tax Court, Second Circuit Court of Appeals, the United States Supreme Court, and the Federal District Courts of the District of Columbia, Connecticut, Massachusetts, and New York (Southern and Eastern). He has been listed in the 2008 Guide to the World's Leading Transfer Pricing Advisers.

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Robert T. Cole
Senior Counsel
Alston and Bird LLP

Bob Cole is founding chair of the firm’s International Tax Group. He concentrates his practice on transfer pricing, tax treaties and other international tax issues for U.S. business operations abroad, foreign business operations in the United States and for U.S. investments of wealthy families.

In his transfer pricing practice, he assists multinationals in a variety of contexts, including the development and contractual implementation of worldwide transfer pricing systems, advising on transfer pricing issues in connection with mergers and acquisitions and spin-offs, advising on and implementing cost sharing arrangements, advising on the self-compliance and documentation process needed to avoid transfer pricing penalties in the United States and other countries, counseling with respect to U.S. and foreign tax audits, representation in domestic dispute resolution proceedings, representation in Competent Authority proceedings under tax treaties, representation in securing advance pricing agreements (APAs), and lobbying on regulations.

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Transfer Pricing 101 LIVE Webcast
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