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Understanding New IRS Rules That Restrict Profits Sent Overseas
Alan Shapiro
Partner, Global Transfer Pricing
Deloitte Tax LLP
Alan Shapiro is a partner in the Chicago office of Deloitte Tax LLP, and a member of the national transfer pricing team. He works with the firm's largest U.S. and non-U.S. multinational companies to develop and implement transfer pricing strategies. He has over 30 years of experience, of which the last 20 years have been devoted to specializing in the full range of transfer pricing issues.
Mr. Shapiro is one of the firm's leading experts on the cross-border taxation of intangible property, including the development of transfer pricing regimes that focus on minimizing the worldwide tax imposed on intangible property. He has represented clients in controversies with the IRS and in competent authority proceedings between U.S. and foreign tax authorities. His industry experience includes the automotive, pharmaceuticals, electronic components, high tech, software, and consumer products sectors.
Mr. Shapiro was selected for inclusion in the 2007 and 2009 editions of The Best of the Best USA in the category of transfer pricing advisors, in the 2002-2008 editions of the Guide to the World's Leading Transfer Pricing Advisers, and in the 2003-2009 editions of the Guide to the World's Leading Tax Advisers. He is widely quoted on transfer pricing topics in BNA's Daily Tax Report and Transfer Pricing Report and has authored or coauthored numerous articles on transfer pricing subjects, including “The New US Cost Sharing Regulations: Past, Present and Future”, to be published by BNA Tax Management Memorandum; "New Services and Intangible Regulations: IRS Changes the Mix," 15 BNA Transfer Pricing Report 308 (August 16, 2006); "Proposed Cost Sharing Regulations: Are They a Realistic Alternative?," 109 Tax Notes 239 (October 10, 2005); several chapters for Intellectual Property (International Tax Review's Tax Reference Library 12, 2003); "Proposed Cost Sharing Stock Option Regulations," Tax Planning International: Transfer Pricing (February 2003); "Proposed Rev. Proc. 65-17: Update Raises Many Issues," BNA Transfer Pricing Report (January 13, 1999); "Planning Opportunities Under the Final U.S. Cost-Sharing Regulations," IBFD International Transfer Pricing Journal (March/April 1998); and "Lost in Cyberspace: Transfer Pricing Aspects of Proposed §861 Computer Software Regulations," BNA Transfer Pricing Report (December 12, 1996).
Mr. Shapiro holds an LLM (Tax) and a JD from Georgetown University Law School, and an MA (Economics) and a BS (Business Administration) from Boston University. Mr. Shapiro is a member of the Bar of the State of Pennsylvania and is a certified public accountant.
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.
Jon Silverman
Ph.D., Principal, Global Transfer Pricing Services
KPMG
Dr. Jon Silverman is the Principal-In-Charge of KPMG’s western region Economic and Valuation Services (EVS) practice. Dr. Silverman has twenty five years of consulting experience and provides transfer pricing, tax valuation, and other economic services to KPMG’s clients. Jon also plays a national role as lead principal for the EVS Economic services line of business.
Prior to joining KPMG, Dr. Silverman was a senior associate at DRI/McGraw Hill, where he provided consulting support to users of DRI’s macroeconomic, regional, industry, and energy models. He was also responsible for the management and development of some large-scale economic information systems for DRI’s energy and government practices. Dr. Silverman also spent five years at the Bureau of Economic Analysis where he was responsible for preparing forecasts of the U.S. economy and using the BEA macro model to analyze topical policy issues.
Education, Licenses & Certifications: PhD in economics from George Mason University; BA and MA in economics from Boston University
Kent Wisner
Principal, International Corporate Services, California
KPMG
Kent is a frequent author of articles and speaker for seminars on various aspects of international taxation. He is also a member of the State Bars of California, Illinois, the District of Colombia and Virginia. He is an adjunct member of the faculty at the Law School at Boalt Hall, the University of California at Berkeley, where he has taught a course in International Taxation Law since 2001. He also has been a frequent guest lecturer at the Haas School of Business at UC Berkeley in courses in International Finance.
Kent holds a Juris Doctor degree from University of Virginia, where he was a member of the Virginia Law Review; a Masters Degree in Law and Diplomacy from The Fletcher School of Law and Diplomacy at Tufts University; and a Bachelor’s Degree, with distinction, in International Relations and Russian from Stanford University.
Understanding New IRS Rules That Restrict Profits Sent Overseas
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