Prior Experience
Mike was an attorney in the IRS Chief Counsel's Office for 15 years. He had national responsibility at IRS for technical issues, regulations and litigation of cases relating to transfer pricing. Mike was editor of and a major contributor to the Treasury/IRS Transfer Pricing White Paper. The White Paper laid the theoretical ground work for the profit-based transfer pricing methods adopted by the US and the OECD, established principles for implementing R&D cost sharing arrangements, set forth guidelines for applying US "commensurate with income" adjustments and made recommendations for transfer pricing documentation and penalty provisions that have been adopted in over 40 countries. He was the lead US Treasury negotiator in many negotiations with foreign governments and US possessions for tax information exchange agreements.
Recognitions
Mike was recently recognized as a winner in the Transfer Pricing category by Corporate LiveWire at its Global Awards 2016. In addition, he was named International Transfer Pricing Advisor of the Year by ACQ Magazine at its Global Awards 2015. In addition, he has been named one of the Best of the Best US transfer pricing advisors as well as one of the leading Asia Pacific tax advisors by Euromoney and the Legal Media Group. For many years he has been named a "Highly Recommended" tax advisor by International Tax Review.