Transfer Pricing guru, Donna McComber, returns to Bakers as Director of Economics

Donna McComber, a highly regarded transfer pricing economist with the Internal Revenue Service, has rejoined Baker & McKenzie Consulting LLC as a Director of Economics.

Based in Washington, DC, Ms. McComber spent the last 10 years with the IRS, most recently serving as Assistant Director of the agency’s Advance Pricing and Mutual Agreement Program. Prior to joining the IRS in 2006, Ms. McComber was a Senior Economist with Baker & McKenzie.

At the IRS, Ms. McComber was involved in some of the most difficult cases in APMA’s inventory, including intangibles migration, restructuring, and financial product cases. In addition to making strategic and policy decisions involving procedural and technical issues, Ms. McComber also reviewed numerous Advance Pricing Agreements and Mutual Agreements for a range of treaty partners.

In addition, McComber led competent authority negotiations with China, Denmark, Germany, Japan, Mexico, Switzerland and the United Kingdom, and was a critical contributor to negotiations with other treaty partners, including Australia, Canada, and Korea.

“Donna is well known in the transfer pricing community and brings a wealth of knowledge from the government side in negotiating APAs and resolving MAP issues, two procedures that are highly important to companies engaging in cross-border transactions with related parties,” said Tom Linguanti, Chair of the Firm’s North American Tax Practice. “In addition, Donna’s insights into the perspectives of numerous US treaty partners will immediately benefit our clients. We are very pleased to have her back on the team.”

In her role with the IRS, Ms. McComber developed a focus on discount rates and cost-sharing, playing a critical role in drafting the IRS’s cost-sharing regulations. She also assisted the IRS Chief Counsel in reviewing appeals and audit cases for specific issues, including pre-tax/post-tax issues, discount rate issues and useful life issues.

“Many of our clients seek insights on the complexities of the cost-sharing regulations for the purposes of both planning and compliance, and Donna’s unique experience with the IRS in developing these rules will further strengthen and deepen our transfer pricing, regulatory, and controversy capabilities,” added Mr. Linguanti.

Ms. McComber is the latest in a series of prominent hires for the Tax Practice in North America. Experienced trust and estates attorney David Berek recently joined in Chicago, and tax planning attorneys Jennifer Molnar, Patrick Cox and Dan Cullen recently joined Washington, DC, New York and Chicago, respectively.