Published Articles & Books

• Where Have All the Transfer Pricing Safe Harbors Gone? A Plea for Reinvigoration
  February 23, 2017
  
• Coca-Cola Company Challenges $9 Billion Transfer Pricing Adjustment
  February 5, 2016
  
• Response to Final OECD BEPS Tome
  October 30, 2015
  
• Transfer Pricing Audits: Flipping the Tested Party
  August 27, 2015
  
• OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns
  November 6, 2014
  
• Remain Vigilant On Indian Permanent Establishments, Even After the Favorable e-Funds Decision
  July 10, 2014
  
• The New APMA Procedures — Cosmetic or Cosmic?
  March 14, 2014
  
• Cruising Toward Safe Harbors for Transfer Pricing?
  March 1, 2013
  
• Safe at Last? Transfer Pricing Safe Harbors on the Horizon
  September 6, 2012
  
• What You Really Need to Know About Transfer Pricing
  July 1, 2012
  
• Short Cuts for Small Fry: Why the IRS Should Reconsider
  April 21, 2011
  
• Survival Techniques: Transfer Pricing in a Sick Economy
  May 1, 2009
  
• Last-Minute Changes and Partial Delays Under New Intercompany Service Rules
  February 1, 2007
  
• Pay Immediate Attention to Far-Reaching Regulations on Intercompany Services
  October 1, 2006
  
• News on the Transfer Pricing Front
  July 1, 2004
  
• Markers and Musings: The Proposed Section 482 Service Regulations
  December 1, 2003
  
• Transfer Pricing: New Rules for Services and Intangibles
  November 1, 2003
  
• Transfer Pricing: IRS Cracking Down on Transfer Pricing Compliance
  April 1, 2003
  
• Option Wars: Upping the Ante for Cost Sharing Arrangements
  November 8, 2002
  
• Second First?? Transfer Pricing Issues In Secondment of Personnel
  September 1, 2002
  
• Cost-Sharing Arrangements Come of Age
  August 28, 2000
  
• Mining For Nuggets in the IRS APA Report
  May 1, 2000
  
• Transfer Pricing Thoughts - North America: More Thoughts On APA Disclosure
  March 1, 2000
  
• A New Way to Resolve a Factual Issue with the IRS Before Filing a Return
  February 21, 2000
  
• Transfer Pricing Thoughts - North America: Thoughts on Code Sec. 482 and Rising Standards of Proof
  December 1, 1999
  
• Transfer Pricing Thoughts - North America: Thoughts on Control
  October 1, 1999
  
• Transfer Pricing Thoughts - North America: Thoughts on Cooperatives
  August 1, 1999
  
• Transfer Pricing Thoughts - North America: Thoughts on APA Disclosure
  June 1, 1999
  
• Transfer Pricing Thoughts - North America: The Euro and the Situs of the Borrower Rule
  April 1, 1999
  
• Transfer Pricing Thoughts - North America: Thoughts on Joint Ventures
  February 1, 1999