John M. Wall brings extensive international tax and US Internal Revenue Service (IRS) leadership experience to his practice, helping businesses navigate transfer pricing, prevent and resolve double taxation, and pursue greater certainty in cross-border transactions. His background spans Advance Pricing Agreements (APAs), Mutual Agreement Procedures (MAPs), tax treaty interpretation, and transfer pricing examinations, including in matters involving billions of dollars in international commerce. He combines deep knowledge of the legal and economic issues underlying intercompany transactions with firsthand insight into tax administration, competent authority negotiations, and dispute resolution.
L.L.M., Taxation, University of Washington School of Law
J.D., University of Montana School of Law
B.S., University of Arizona
EXPERIENCE
John began his career with the IRS in 2008. Over the course of his IRS career, he served in several roles before becoming the Director and Assistant Director of the IRS’s Advance Pricing and Mutual Agreement (APMA) program within the Large Business and International Division. He oversaw APA and MAP negotiations and reviews for hundreds of multinational taxpayers across 30 countries, directing the resolution of complex transfer pricing and tax treaty disputes.
With his decades of experience, John led improvements to competent authority procedures and case processing, including the development of standardized benchmarking approaches to promote consistent, principled outcomes and more efficient resolution of APA and MAP cases. He represented the US as a delegate to the Organization for Economic Cooperation and Development (OECD)’s MAP Forum and chaired its Tax Certainty Focus Group on the Use of Benchmarking.
John's technical work encompassed Internal Revenue Code Section 482, the OECD Transfer Pricing Guidelines, and treaty provisions governing business profits, associated enterprises, and dispute resolution. He worked extensively on the attribution of profits to permanent establishments, including in matters involving complex financial transactions. He frequently speaks at conferences on federal civil tax controversy issues and related topics.
Before joining APMA, John served as an Attorney in the IRS Office of Chief Counsel and as a Special Assistant US Attorney. Prior to that role, he served as a law clerk to the Honorable Harry A. Haines of the US Tax Court.
AWARDS AND RECOGNITION
Deputy Commissioner’s Award for international training, 2021
Deputy Commissioner’s Award for improving the competent authority relationship with India, 2017
