Transfer Pricing Partner resigns from Bakers
Miller & Chevalier Chartered has announced that Robert S. Kirschenbaum has joined the Tax Department as a Member. He comes to the firm from Baker & McKenzie LLP, where he was a partner in that firm’s Transfer Pricing group.
Kirschenbaum is a recognized legal authority in the area of transfer pricing strategy and planning, and related tax controversy resolution. He represents U.S. and foreign-based multinational companies in a wide variety of industry sectors, including software, semiconductor, pharmaceutical, defense, financial services, and retail. A significant part of Kirschenbaum’s practice involves advising high-tech companies based in Silicon Valley. Miller & Chevalier has a long history of advising companies on the West Coast in the tax, employee benefits, litigation, and international trade areas. With the addition of Kirschenbaum and in light of the continued growth of Miller & Chevalier’s client base on the West Coast, the firm is establishing a presence in Palo Alto to provide enhanced service to these clients.
“We are so pleased to welcome Bob Kirschenbaum to the firm,” said Marianna Dyson, Chair, Miller & Chevalier. “He brings a wealth of significant government, industry and private practice experience in the transfer pricing area that will greatly benefit our multinational clients.”
Before joining Baker & McKenzie, Kirschenbaum was Team Leader for the Advance Pricing Agreement (APA) Program of the Internal Revenue Service (IRS). At APA, he was Japan Case Coordinator for the IRS Competent Authority negotiations and was responsible for negotiating and consummating approximately 40 unilateral and bilateral APAs.
“Transfer pricing is one of the most significant issues currently facing global enterprises,” said Patricia Sweeney, Chair of Miller & Chevalier’s Tax Department. “Bob is a recognized leader in the field and has an established reputation for his work helping companies to plan and defend their transfer pricing strategies, while structuring their businesses in a tax-efficient manner. In addition, he shares our commitment to exceptional client service, providing practical advice to meet client needs. Bob will be a valuable addition to our skilled team, which includes lawyers who have both senior government and private practice experience navigating complex matters in the international tax area.”
Transfer pricing presents challenging high-stakes tax issues and planning opportunities for multinationals today and is a critical component of proactively managing global tax obligations. It is also an area of intense focus by U.S. and foreign tax authorities, and significant disputes can arise. Some disputes can be prevented through careful planning or through APAs with one or more tax authorities, while others can be resolved through effective negotiation with taxing authorities and the mutual agreement process under tax treaties. Kirschenbaum has extensive experience assisting multinational companies in designing and implementing transfer pricing strategies and in resolving disputes proactively. His prior government experience serves him well in dealing with taxing authorities around the world.