Eric D. Ryan 资深顾问 [email protected] 电子名片 硅谷 电话： _+1_ 650_ 833_ 2118 传真 _+1_ 650_ 687_ 1192 概述 经验 背景 见解与洞察 新闻 电邮 打印 PDF版本 + 分享 Eric Ryan concentrates in international tax planning, transfer pricing, post merger integration of legal entities, and operations and tax controversy. Eric has over 30 years of experience, both as a tax partner advisor and an internal corporate tax director, on key international tax structuring issues. His clients are primarily in the high technology industry, including software, hardware, digital economy, semiconductors, and life sciences companies. Eric's experience includes advising clients in choice of location and legal entity structures for their operations; conducting direct negotiations for tax rulings in countries such as The Netherlands, Switzerland, Singapore and others; advising on intercompany arrangements that minimize Subpart F and similar tax issues; and advising on intercompany economic terms that seek to maximize profits in appropriate jurisdictions. He advises on the use of holding companies, the valuation of transfer of tangible and intangible property, and the establishment of cost-sharing operations. Eric is experienced in developments of advice pricing agreements (APA's) and intercompany debt and equity. He is also highly experienced with various tax aspects of Stock Based Compensation. Eric is a Pro Bono Coordinator for the East Palo Alto office, and he is also a member of DLA Piper's North American Pro Bono Committee. Eric's pro bono clients include individuals with income tax issues, tax-exempt organizations, domestic violence survivors, and guardians.