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BRIAN C. BECKER,
PH.D. |
Precision Economics, LLC
1901 Pennsylvania Avenue NW, Suite 200
Washington, DC 20006
Tel. (202) 530-1113
Cell (703) 283-9409
Fax. (202) 530-1144
brian@precisionecon.com
www.precisionecon.com
|
EDUCATION |
The Wharton School of the University of Pennsylvania,
Philadelphia, PA
- Ph.D., Applied Economics (1993)
- M.A., Applied Economics (1991)
The Johns Hopkins University, Baltimore, MD
- B.A., Applied Mathematics and Economics (1988)
|
PRESENT
POSITION |
|
Precision
Economics, LLC,
Washington, DC, 2001 - present
President
- Prepared more than 300 transfer pricing reports for taxpayers, the IRS, the Australian Taxation Office, and the Canada Revenue Agency on a variety of issues, including tangible property, cost sharing, intangible property, intercompany loans, guarantee fees, and service fees.
- Served as a lead transfer pricing economic expert for the IRS in the largest transfer pricing dispute and settlement on record, GlaxoSmithKline Holdings (Americas) v. Commissioner of Internal Revenue.
- Provided expert witness testimony—supporting two written reports—in the Tax Court of Canada in the transfer pricing dispute of General Electric Capital Canada Inc. v. Her Majesty the Queen.
- Served as an economic expert witness in the first two major transfer pricing trials in Australia.
- Submitted an expert witness report and provided testimony in United States Tax Court in a transfer pricing dispute.
- Prepared and defended expert reports quantifying damages in the contexts of anti-trust, patent infringement, trade secrets, and professional advice.
- Determined lost sales and profits to a retailer damaged by the 9/11 disaster, in an expert report and in oral testimony before an arbitration panel.
- Provided testimony and economic reports involving catfish, various steel products, and pineapples in hearings before the U.S. International Trade Commission.
- Submitted an economic expert report and provided testimony in an intellectual property and business valuation dispute before Delaware Chancery Court.
- Provided written and oral expert valuation testimony in U.S. Tax Court involving minority interests in a privately held publishing business.
- Submitted economic expert witness affidavits in investor class action litigation involving the specialists of the New York Stock Exchange.
|
EXPERT TESTIMONY, SUBMISSIONS AND HEARINGS |
|
"Valuation Expert Report," United States District Court, Southern District of Florida, Miami Division, Marine Hose Antitrust Litigation, Master Docket No. 08-MDL-1888-GRAHAM/TURNOFF, June 16, 2010, Deposition Testimony, Washington, DC, July 9, 2010.
"Second Statement of Brian Charles Becker," Federal Court of Australia, New South Wales District Registry, Between Devereaux Holdings Pty Limited, Applicant, and The Commissioner of Taxation of the Commonwealth of Australia, Respondent, June 30, 2010.
"Statement of Brian Charles Becker," Federal Court of Australia, New South Wales District Registry, Between Devereaux Holdings Pty Limited, Applicant, and The Commissioner of Taxation of the Commonwealth of Australia, Respondent, March 31, 2010.
"Economic Analysis of the Transfer Prices Between Weekend Warrior Trailers, Inc. and Leading Edge Designs, Inc.: 2002-2004," United States Tax Court, Weekend Warrior Trailers, Inc. et al, Petitioner, v. Commissioner of Internal Revenue, Respondent, Docket Nos. 6984-08, 6997-08, and 15166-08, January 22, 2010, Direct and Cross Examination Testimony, San Diego, California, February 23, 2010.
"Third Statement of Brian C. Becker," Federal Court of Australia, Victoria District Registry, Between SNF (Australia) PTY Limited, Applicant, and The Commissioner of Taxation of the Commonwealth of Australia, Respondent, May 15, 2009, Direct and Cross Examination Testimony, Melbourne, Australia, July 29-30, 2009.
"Second Statement of Brian C. Becker," Federal Court of Australia, Victoria District Registry, Between SNF (Australia) PTY Limited, Applicant, and The Commissioner of Taxation of the Commonwealth of Australia, Respondent, March 23, 2009, Direct and Cross Examination Testimony, Melbourne, Australia, July 29-30, 2009.
"Statement of Brian C. Becker," Federal Court of Australia, Victoria District Registry, Between SNF (Australia) PTY Limited, Applicant, and The Commissioner of Taxation of the Commonwealth of Australia, Respondent, March 2, 2009, Direct and Cross Examination Testimony, Melbourne, Australia, July 29-30, 2009.
"Economic Analysis of the Taxpayer’s Expert Reports in the Matter of Guarantees Made by General Electric Capital Corporation to General Electric Capital Canada, Inc.: 1996–2000," General Electric Capital Canada Inc. v. Her Majesty the Queen, Tax Court of Canada, 2006-1385(IT)G, May 7, 2009, Direct and Cross Examination Testimony, Toronto, Canada, June 17, 2009.
"Economic Analysis of the Guarantees Made by General Electric Capital Corporation to General Electric Capital Canada, Inc.: 1996–2000," General Electric Capital Canada Inc. v. Her Majesty the Queen, Tax Court of Canada, 2006-1385(IT)G, April 14, 2009, Direct and Cross Examination Testimony, Toronto, Canada, June 17, 2009.
"Damages Rebuttal Expert Report," United States District Court, Southern District of Florida, Case No. 07-80826, June 16, 2008, Deposition Testimony, Washington, DC, June 27, 2008.
"Statement of Brian
C. Becker," Roche Products Pty. Ltd. vs. Federal Commissioner of Taxation, Administrative Appeals
Tribunal, Taxation Appeals Division, New South
Wales District Registry, NO NT7 AND NT56-65 OF
2005, August 30, 2007, Direct
and Cross Examination Testimony, Sydney, Australia, February 20-21,
2008.
"Leslie J. Leff et.
al., v. Morgan Lewis & Bockius, LLP: Valuation
Expert Report," JAMS Arbitration
Hearing, March 15, 2007, Direct
and Cross Examination Testimony, Philadelphia, PA, April 19, 2007.
"Assessing
the Impact of Revoking Antidumping Orders on Canned
Pineapple Fruit from Thailand on the Domestic
Industry," in Canned Pineapple Fruit from
Thailand, Investigations No. 731-TA-706 (Second
Review), United States International Trade Commission,
with A. Parsons, January 5,
2007.
"Affidavit
of Brian C. Becker, Ph.D. in Support of Plaintiffs'
Initial Discovery Plan," in CALIFORNIA
PUBLIC EMPLOYEES' RETIREMENT SYSTEM, On Behalf
of Itself and All Others Similarly Situated vs.
THE NEW YORK STOCK EXCHANGE, INC., et. al., United
States District Court, Southern District of New
York, Civil Action No. 03-CV-9968-UA, May 23,
2006.
"Affidavit
of Brian C. Becker" and "Economic
Analysis of Sales Dispersion And "Make-Up" Sales,"
in Re Appraisal Between, DUANE READE, INC., and
ST. PAUL FIRE AND MARINE INSURANCE COMPANY, December
16, 2004, Appraisal Panel Hearing, Direct and Cross Examination Testimony,
April 27, 2005.
"The Steel
Industry: An Automotive Supplier Perspective,"
in Certain Hot-Rolled Flat-Rolled Carbon-Quality
Steel Products from Brazil, Japan, and Russia,
Investigations Nos. 701-TA-384 and 731-TA-806-808
(Review), United States International Trade Commission, Testimony at Hearing, March 2, 2005.
"Affidavit
of Brian C. Becker, Ph.D., Submitted in Support
of Defendant's Motion to Dismiss the Indictment
and Inspect the Grand Jury Minutes," in
THE PEOPLE OF THE STATE OF NEW YORK, against THEODORE
C. SIHPOL, Indictment No. 1710/2004, Supreme Court
of the State of New York, County of New York,
February 9, 2005.
"Fair Market
Value Estimate of the But-For Commissions Earned
by Maitake Products, Inc. from August 17, 2001
Through April 10, 2006," in MAITAKE PRODUCTS,
INC., AND SUN MEDICA CO., LTD., v. TRANS-HERBE,
INC., Superior Court of New Jersey Law Division
- Bergen County, Docket No: L-9476-02, December
10, 2004, Deposition Testimony, January 28, 2005.
"Economic Analysis
of Colortyme's Lost Profits," in DL KING,
LLC D/B/A COLORTYME, v. KEVIN COLEMAN AND ABC
TELEVISION & APPLICANCE RENTAL, INC., D/B/A PRIME
TIME RENTALS, Circuit Court of Halifax County,
Virginia, Case No. CH02000102-00, August 18, 2004.
"Affidavit
of Brian C. Becker," in KEITH PARKS, et.
al., Individually, and on Behalf of Others Similarly
Situated, v. GOLD KIST, INC., et. al., Superior
Court of Dekalb County, Georgia, Civil Action
Case No. 04-CV-7263-4, August 10, 2004, Deposition
Testimony, August 24, 2004.
"Punitive Damages
Report," in KATHLEEN McCORMACK et al. v.
WYETH et al., Superior Court of the District of
Columbia, Civil Case No. 02-CA-6082, Deposition
Testimony, May 20, 2004.
"Third Affidavit
of Brian C. Becker, Ph.D.," in CALIFORNIA
PUBLIC EMPLOYEES' RETIREMENT SYSTEM, On Behalf
of Itself and All Others Similarly Situated vs.
THE NEW YORK STOCK EXCHANGE, INC., et. al., United
States District Court, Southern District of New
York, Civil Action No. 03-CV-9968-UA, April 6,
2004.
"Second Affidavit
of Brian C. Becker, Ph.D.," in CALIFORNIA
PUBLIC EMPLOYEES' RETIREMENT SYSTEM, On Behalf
of Itself and All Others Similarly Situated vs.
THE NEW YORK STOCK EXCHANGE, INC., et. al., United
States District Court, Southern District of New
York, Civil Action No. 03-CV-9968-UA, January
16, 2004.
"Affidavit
of Brian C. Becker, Ph.D.," in CALIFORNIA
PUBLIC EMPLOYEES' RETIREMENT SYSTEM, On Behalf
of Itself and All Others Similarly Situated vs.
THE NEW YORK STOCK EXCHANGE, INC., et. al., United
States District Court, Southern District of New
York, Civil Action No. 03-CV-9968-UA, January
6, 2004.
"Assessing
the Impact of Imported Frozen Basa and Tra Fillets
from Vietnam on the U.S. Frozen Catfish Fillet
Industry," United States International
Trade Commission, Inv. No. 731-TA-1012 (Final,
with A. Salzberg), submitted June 11, 2003, Testimony
at Hearing, June 17, 2003.
"Valuation
of Estate of Josephine Thompson's Shares in Thomas
Publishing Company as of May 2, 1998,"
submitted February 14, 2003 and "Rebuttal
Valuation of Estate of Josephine Thompson's Shares
in Thomas Publishing Company," submitted
May 27, 2003 in Estate of Josephine T. Thompson
v. Commissioner of Internal Revenue, U.S. Tax Court, No. 4939-02. Direct and Cross Examination
Testimony, New York, NY, June 4-5, 2003.
"Analysis of
Xentex's Expenses," in Xentex Technologies,
Inc., Chapter 11 Reorganization, Motion of TMB,
LLC for an Order Appointing a Chapter 11 Trustee,
United States Bankruptcy Court for the Northern
District of Illinois Eastern Division, Deposition
Testimony, April 23, 2003.
"Insolvency
Analysis Regarding Xentex Technologies, Inc. as
of February 7, 2003," in Xen Investors,
LLC v. Xentex Technologies, Inc., C.A. NO. 19713
NC In the Court of Chancery for the State of Delaware
in and for New Castle County, Report Submitted
February 7, 2003; Deposition Testimony February
27, 2003; Direct and Cross Examination
Testimony, March 4, 2003.
"Economic Testimony,"
United States International Trade Commission,
Inv. Nos. 731-TA-986 and 987 (Final), Testimony
at Hearing, November 22, 2002.
"The State
of Venture Capital Investment in the U.S. Telecommunications
Sector," White Paper Submission to the
Federal Communications Commission Regarding Spectrum
Auction 46, Washington, DC, September 20, 2002.
"Economic Damages
Report," In: Jerry Brown vs. Education
Services International, Judicial Arbitration and
Mediation Services, Inc. (JAMS) Arbitration, Washington,
DC, April 4, 2002 (written testimony).
"Economic Testimony,"
United States International Trade Commission,
Inv. Nos. 731-TA-986 and 987 (P), Testimony at Hearing, December 17, 2001.
"COMPAS Economic
Analysis of Various Quota Remedies for Hot Bar/Light
Shaped Steel, Rebar, and Welded Tubular Products
(Products 9, 11, and 20)," United States
International Trade Commission, Inv. No. TA-201-73,
Pre-hearing report filed October 29, 2001, Testimony at Hearing, November 8, 2001, Post-hearing report filed November 14, 2001.
"Expert Report
of Brian C. Becker, Ph.D.," In: Muze, Inc.
vs. Alliance Entertainment Corp; Matrix Software,
Inc., and Eric Weisman; and Michael Erlewine;
and Does 1 through 10, inclusive, March 2, 2001,
United States District Court, Central District
of California, Western Division, Case No. 00 -
00620 RSWL (CWx), Deposition Testimony, April
3, 2001.
"Economic Expert
Report In: William A. Clutter d/b/a BC Transportation
Consultants, Petitioner v. Transportation Services
Authority of Nevada, Respondent," December
11, 2000, District Court, Clark County, Nevada,
Case No. A387827, Dept. No. VII, Docket No. P.(written
report and affidavit).
"Economists'
Expert Report on Uzbekistan Imports, An Economic
Assessment of the Impact of Termination of the
Investigation of Uranium Imports from Uzbekistan,"
United States International Trade Commission,
Inv. Nos. 731-TA-539-C, E and F (Review), Report
filed June 5, 2000, Testimony at Hearing, June 13, 2000 (with
A. Wechsler).
Economic Witness
on Uranium from Kazakhstan, United States
International Trade Commission, Inv. No. 731-TA-539-A
(Final), United States International Trade Commission,
Testimony at Hearing, June 9, 1999 (with A. Wechsler).
"Expert Report
In the Matter of Dumped Certain Prepared Baby
Foods Originating in or Exported from The United
States of America," The Canadian International
Trade Tribunal Public Interest Inquiry No. PB-98-001,
August 10, 1998. Direct and Cross Examination
Testimony, September
15, 1998.
Economic Witness
on Changed Circumstances Review for Titanium Sponge
from Japan, Kazakhstan, Russia, and Ukraine,
United States International Trade Commission,
Testimony at Hearing, June 8, 1998.
Witness on
Economic Methodologies Panel for Proposed Amendments
to Rules of Practice and Procedure; Five-Year
Reviews, United States International Trade Commission,
Testimony at Hearing, February 26, 1998.
"An Economic
Analysis of the Compensation paid to Executives
of the Dexsil Corporation 1989-1990," executive
compensation case # 1349-93, United States Tax
Court, June 8, 1994 (written testimony, with G.
Godshaw).
|
PUBLISHED PAPERS AND BOOK CHAPTERS |
- "Projected and Actual Profits’ Impact on Licensees," Tax Management Transfer Pricing Report, Vol. 17, No. 11, October 9, 2008, pp. 461-466.
- "The
Economics of Cost Sharing Buy-Ins: Questions
and Answers," Tax Management Transfer
Pricing Report, Vol. 16, No. 24, April 24, 2008,
pp. 950-953.
- "Benchmarking
Manufacturing or Distribution Entities Against
the Profits of Consolidated Companies,"
Tax Management Transfer Pricing Report, Vol.
13, No. 5, July 7, 2004, pp. 236-237.
- "An Examination
of Goodwill Valuation Methodologies," Corporate
Governance Advisor, Vol. 10, No. 4, July/August
2002, pp. 35-40 (with M. Riedy and K. Sperduto).
- "Comparable
Profits Method: Accounting for Margin and Volume
Effects of Intangibles," Tax
Management Transfer Pricing Report, Vol.
10, No. 19, February 6, 2002, pp. 831-833.
- "Cost Sharing
Buy-Ins," Chapter
in Transfer Pricing Handbook, 3rd Edition,
and Transfer Pricing
International, edited by Robert Feinschreiber,
John Wiley & Sons, 2002, pp. A-3 - A-16.
- "Cost Sharing
Buy-Ins," Corporate
Business Taxation Monthly, Vol. 3, No.
3, December 2001, pp. 26-35.
- "Further
Thoughts on Cost Sharing Buy-Ins: A Review of
the Market Capitalization and Declining Royalty
Methods," Tax
Management Transfer Pricing Report, Vol.
10, No. 6, July 11, 2001, pp. 195-197.
- "Valuing
In-Process R&D for Acquisitions: Economic Principles
Applied to Accounting Definitions," Tax
Management Transfer Pricing Report, Vol.
9, No. 10, September 20, 2000, pp. 323-326.
- "Should
a Blockage Discount Apply? Perspectives of Both
A Hypothetical Willing Buyer and A Hypothetical
Willing Seller," Business
Valuation Review, Vol. 19, No. 1, March
2000, pp. 3-9 (with G. Gutzler).
- "Does a
Small Firm Effect Exist when Using the CAPM? Not
Since 1980 and Not when Using Geometric Means
of Historical Returns," Business
Valuation Review, Vol. 18, No. 3, September
1999, pp. 104-111 (with I. Gray).
- "Transfer
Pricing and Foreign Exchange Risk," Tax
Management Transfer Pricing Report, Vol.
8, No. 6, July 14, 1999, pp. 251-256 (with M.
Bajaj and J. Neuberger).
- "The Control
Premium: An Initial Look Into a Strict Monetary
Value Approach," Business
Valuation Digest, Vol. 5, No. 1, July
1999, pp. 12-15.
- "Using Average
Historical Data for Risk Premium Estimates: Arithmetic
Mean, Geometric Mean, or Something Else?,"
Business Valuation Review,
December 1998, Vol. 17, No. 4, pp. 136-140 (with
I. Gray).
- "The Cost
of Carry: An Inflation Adjustment to Assure
Consistent Real Profit Margins," Tax
Management Transfer Pricing Report, Vol.
7, No. 17, December 23, 1998, pp. 639-643 (with
B. Brooks).
- "The Peculiar
Market for Commercial Property: The Economics
of 'Improving' a Rental Property," The
Southwestern Journal of Economics, July
1998, Vol. II, No. 2, pp. 104-121.
- "The Effects
of Inflation on Cross-Country Profit Comparisons,"
Tax Management Transfer
Pricing Report, Vol. 7, No. 3, June 3,
1998, pp. 77-82 (with B. Brooks).
- "Quantifying
Comparability for Applications in Economic Analysis: The
Weighted Distance Method," The
Southwestern Journal of Economics, Volume
2, Number 1, April 1997, pp. 128-141 (with K.
Button).
- "Minority
Interests in Market Valuation: An Adjustment
Procedure," Business
Valuation Review, Volume 16, Number 1,
March 1997, pp. 27-31.
- "Capital
Adjustments: A Short Overview," Tax
Management Transfer Pricing Report, Vol.
5, No. 19, January 29, 1997, pp. 613-619.
- "Multiple
Approaches to Valuation: The Use of Sensitivity
Analysis," Business
Valuation Review, Volume 15, Number 4,
December 1996, pp. 157-160.
- "The Robin
Hood Bias: A Study of Biased Damage Awards,"
The Journal of Forensic
Economics, Volume 9, No. 3, Fall 1996,
pp. 249-259.
- "Three Technical
Aspects of Transfer Pricing Practice: Distinguishing
Methods, Using Statistical Ranges, and Developing
Data Sets," Tax
Management Transfer Pricing Report, Vol.
5, No. 4, June 19, 1996, pp. 97-103.
- "The Final
Transfer Pricing Regulations: The More Things
Change, the More they Stay the Same,"
Tax Notes, Volume
64, #4, pp. 507-523, 1994 (with G. Carlson,
et. al.).
- "Philadelphia's
Luxury Hotels: Boom or Bust?," The
Cornell Hotel and Restaurant Administration
Quarterly, Volume 33, #2, pp. 33-42,
1992.
|
PROFESSIONAL SEMINARS |
|
"Transfer Pricing," Guest Lecturer at The Georgetown University
Law School, November 5, 2009.
"Fundamentals of
Transfer Pricing," Conference Chair, IIR Seminar, London, UK, October 29, 2008.
"Fundamentals of
Transfer Pricing," Speaker on Transfer
Pricing Methods, IIR Seminar, London, UK, June
11, 2008.
"Transfer Pricing,"
Guest Lecturer at The George Washington University
Law School, March 26, 2008.
"Economics of Private
Student Loans," Speaker on the 2008
National Council of Higher Education Loan Programs
Leadership Conference: As the Dust Settles, Sarasota,
FL, January 9, 2008.
"Economists in Transfer
Pricing: Intangibles, Audits, and APAs,"
Council for International Tax Education, Inc.:
U.S. Transfer Pricing Planning and Controversies,
Houston, TX, October 15, 2007.
"New IRS Rules for
Transfer Pricing of Services," Strafford
Publications Teleconference Speaker on Methods
and Services Sharing Agreements, July 10, 2007.
"New IRS Rules for
Transfer Pricing of Services," Strafford
Publications Teleconference Speaker on Methods
and Services Sharing Agreements, May 8, 2007.
"Economists in Transfer
Pricing: Intangibles, Audits, and APAs,"
Council for International Tax Education, Inc.:
U.S. Transfer Pricing Planning and Controversies,
Washington, DC, April 23, 2007.
"Profitability and
R&D for PhRMA," Pharmaceutical
Research and Manufacturers of America Conference,
Charlottesville, VA, January 26, 2007.
"Economics of Mass
Tort: Lead Paint," Gerson Lehrman
Group Seminar, New York, NY, November 16, 2005.
"Understanding the Issues Involved in the
Valuation of Intangibles," Transfer
Pricing: Best Practices for Managing the Corporate
Transfer Pricing Function, Infonex Seminar, San
Francisco, CA, October 27, 2005.
"Maximizing Revenue, Minimizing Taxpayer
Burden," Emcee and Speaker for Discussion
of "Revenue Matters," National Press
Club, Washington, DC, June 7, 2005.
"Intangible Valuation in Transfer Pricing,"
Transfer Pricing Roundtable: Best in Class Practices
for Companies, Infonex Seminar, New York, NY,
May 25, 2005.
"Transfer Pricing
Workshop," Workshop Chair and Speaker,
IIR Ltd., London, UK, April 25, 2005.
"The Steel Industry:
An Automotive Supplier Perspective,"
National Press Club, Washington, DC, February
16, 2005 (with Kevin Hassett.)
"Probability and Statistics,"
Digital Sandbox Risk Analysis Seminar Series,
Reston, Virginia, October 14, 2004.
"The Economics of
Transfer Pricing: Independent Arm’s Length
Analysis," Council for International
Tax Education: U.S. Transfer Pricing Planning
& Controversies, New York, NY, August 16,
2004.
"Transfer Pricing
Workshop," Workshop Chair and Speaker,
IIR Ltd., London, UK, April 21, 2004.
"Economists in Transfer
Pricing: Independence, Methodologies, and Case
Study," Council for International
Tax Education: U.S. Transfer Pricing 101, New
York, NY, February 23, 2004.
"Profitability Analysis
of NYSE Trading Specialists," American
Enterprise Institute Seminar Series, Washington,
DC, October 8, 2003.
"Economists in Transfer
Pricing: Independence, Cost Sharing, and CPM Volume
Effects," Council for International
Tax Education: U.S. Transfer Pricing Planning
& Compliance, New York, NY, August 18, 2003.
"Economists in Transfer Pricing: Profit
Splits, Volume Effects, Cost Sharing, and Real
Options," Council for International
Tax Education: U.S. Transfer Pricing Planning
& Compliance, Washington, DC, May 6, 2003.
"Economists in Transfer
Pricing: Profit Splits, Volume Effects, Cost Sharing,
and Real Options," Council for International
Tax Education: U.S. Transfer Pricing Planning
& Compliance, Dallas, TX, March 24, 2003.
"Topics in Transfer Pricing and Valuation,"
Conference Chair, Discussion Topics "Cost
Sharing Buy-In Valuations" and "Volume
Effects of Intangibles," Internal Revenue
Service, Washington, DC, December 9-10, 2002.
"Economists in Transfer Pricing: Cost Sharing
and Real Options," Council for International
Tax Education: U.S. Transfer Pricing Planning
& Compliance, New York, NY, September 23,
2002.
"Valuation of Intangible
Property and Cost Sharing Arrangements,"
Economist Group of the Internal Revenue Service,
San Francisco, CA, June 25, 2002.
"Valuation of Intangible
Property and Cost Sharing Arrangements,"
Southeast Region of Internal Revenue Service,
Atlanta, GA, May 10, 2002.
"Economists in Transfer
Pricing: CPM and Cost Sharing," Council
for International Tax Education: U.S. Transfer
Pricing Planning & Compliance, Washington,
DC, May 6-7, 2002.
"Pricing Cost Sharing
Buy-Ins and Other Intercompany Transfers,"
Council for International Tax Education: U.S.
Transfer Pricing Planning & Compliance, New
York, NY, November 15-16, 2001.
"Pricing Cost Sharing
Buy-Ins and Other Intercompany Transfers,"
ATLAS Intermediate U.S. International Tax Update,
Cleveland, Ohio, November 5, 2001.
"Cost Sharing Buy-Ins:
Market Capitalization, Declining Royalty, and
Other Methods," Internal Revenue
Service Annual Economist Convention, Washington,
DC, July 25, 2001.
"The Relative Values
of Early and Late Stage Research & Development,"
presentation to Shaw Pittman, McLean, Virginia,
March 28, 2001.
"Valuation Concepts
in Family Limited Partnerships,"
two hour presentation to Internal Revenue Service
Northeast Engineers, Fort Monmouth, New Jersey,
August 30, 2000.
"The Discounted Cash Flow Method and Other
Valuation Concepts," two hour presentation
to IRS Kansas and Missouri District Estate &
Gift Tax attorneys and managers, Kansas City,
Kansas, October 4, 1999.
"The Discounted Cash
Flow Method and Other Valuation Concepts,"
presentation to IRS New York District Estate &
Gift Tax attorneys and managers, New York, NY,
August 16, 1999.
"Business Valuation,"
national closed circuit televised broadcast for
Internal Revenue Service Estate Tax Agents, September
23, 1997 (with J. Murphy).
"Valuation and Finance
Principles Applied to Transfer Pricing,"
a presentation to IRS and Treasury Department
economists, Washington, DC, September 11, 1997
(with T. Reichert).
"The Peculiar Market
for Commercial Property: An Economically Irrational
Situation," Southwestern Economics
Association Annual Meeting, Houston, Texas, March
23, 1996.
"The Robin Hood Bias:
A Study of Biased Damage Awards,"
Southwestern Economics Association Annual Meeting,
Houston, Texas, March 22, 1996.
"Quantifying Comparability
for Applications in International Trade and Intercompany
Transfer Pricing: The Weighted Distance Method
of Analyzing Comparability," Southwestern
Economics Association Annual Meeting, Houston,
Texas, March 21, 1996.
"Some Economic Issues
in Transfer Pricing," World Trade
Institute: Tax Aspects of Intercompany Transfer
Pricing, New York, NY, November 9-10, 1995.
|
MEDIA AND AWARDS |
Inclusion in Euromoney's "Expert Guide to the World's Leading Transfer Pricing Advisors," 2010.
Bloomberg Television Interview, New York Stock
Exchange Trading Specialists, October 8, 2003.
"Valuation
Evaluation: How to Determine the Size of Interest
in an LLC," CFO.com, Ask the Experts, August
31, 2001.
|
CONSULTING EXPERIENCE |
CRITERION FINANCE, L.L.C., Washington,
DC, 2001 - 2001
Partner and Senior Vice President
- Authored expert reports and articles on various
transfer pricing topics, including cost sharing
buy-ins.
- Wrote an expert report and provided deposition
testimony estimating damages to a music database
corporation from the anti-competitive acts of
a competitor.
LECG, LLC, Washington, DC, 1999 - 2001
Senior Managing Economist
- Served as an economic expert in a pharmaceutical
patent dispute regarding the relative values
of early and late stage compounds.
- Submitted expert report on the process used
to determine financial viability for state certified
transportation services.
ECONOMIC CONSULTING SERVICES INC., Washington,
DC, 1995 - 1999
Senior Economist (promoted from Economist)
- Analyzed transfer prices for corporations
in a number of industries, including oil products,
pharmaceuticals, consumer products, and software.
- Testified as an economic expert in international
trade matters before the Canadian International
Trade Tribunal and the U.S. International Trade
Commission.
ARTHUR ANDERSEN, L.L.P., Washington,
DC, 1994 - 1995
Manager, Economics Group
- Directed more than 20 transfer pricing studies.
- Submitted an expert witness report on executive
compensation in Tax Court.
DELOITTE & TOUCHE NATIONAL TAX OFFICE,
Washington, DC, 1992 - 1994
Senior Consultant, Economics Group
- Performed numerous tax economic analyses,
primarily transfer pricing.
- Participated in seminars regarding transfer
pricing and international taxation.
|
PROFESSORIAL EXPERIENCE |
THE JOHNS HOPKINS UNIVERSITY, Washington,
DC , 1997 - 2002
Visiting Professor of Finance
- MBA level Corporate Finance and Derivative
Security courses.
MARYMOUNT UNIVERSITY, School of Business,
Arlington, VA, 1993 - 1995
Visiting Professor of Statistics
- MBA and undergraduate Statistics courses.
THE GEORGE WASHINGTON UNIVERSITY, School of Business
and Policy Management, Washington, D.C., 1992 - 1993
Visiting Professor of Management Science
- MBA level Productions and Operations Management
course.
UNIVERSITY OF PENNSYLVANIA, The Wharton School
of Business, Decision Sciences Department, Philadelphia,
PA, 1988 - 1990
Instructor
- Undergraduate level Computer Applications
courses.
July 2010 |
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