Ednaldo Silva
Dr. Ednaldo Silva is Founder & Director of RoyaltyStat, a leading online database of royalty rates extracted from unredacted license agreements filed with the SEC.
He is an economist with over 25 years of experience in transfer pricing innovation and the valuation of intangibles.
Dr. Silva helped draft the US transfer pricing regulations as Senior Economic Adviser in the IRS Office of Chief Counsel. He was the originator and developer of the “comparable profits method” and introduced the best method rule and the concept that arm’s length is represented by a range of results. Dr. Silva was also the first economist in the IRS's Advance Pricing Agreement (APA) Program.
Latest posts by Ednaldo Silva (see all)
- US Tax Court decision in Coca-Cola is at odds with economic principles - March 3, 2021
- Transfer pricing and the cumulative advertising effects on sales - January 20, 2021
- The origins of transfer pricing’s comparable profits method - January 6, 2021
- Transactional profit indicators for the TNMM are not viable - December 9, 2020
- A proposed transfer pricing safe harbor for US retailers - November 24, 2020
Amanda Varma
Amanda Varma advises clients on US federal income tax matters, with particular focus on international tax planning and controversies.
Her practice includes counseling domestic and foreign businesses with respect to cross-border acquisitions, business restructurings, and financings, tax treaty matters, deferral and foreign tax credit issues, transfer pricing, and withholding and reporting issues.
She also regularly advises clients on special issues arising in international tax controversies, including competent authority and information exchange. Ms. Varma also represents clients in connection with regulatory and legislative tax policy matters.
Latest posts by Amanda Varma (see all)
- The final and proposed BEAT regulations: what changed, what’s new, and what’s next? - December 11, 2019
- US court invalidates “serial inversion” tax regulation that ended Pfizer-Allergen merger - October 10, 2017
- Key takeaways from the proposed foreign tax credit regulations - December 19, 2018
- Five highlights from the IRS’s proposed GILTI regulations - October 1, 2018
- US and Ireland commence tax treaty renegotiation: what could change - August 31, 2016
Monte Jackel
Latest posts by Monte Jackel (see all)
- US Tax Court decision in Grecian Magnesite could upend international tax regime for partnerships - July 18, 2017
- Trump’s tax regulation order: what (besides earnings stripping) could be on the chopping block? - April 24, 2017
- US Tax Court decision has big implications for non-US partners in US partnerships - July 16, 2017
- Why the House GOP’s destination-based cash flow tax doesn’t work for partnerships - March 13, 2017
- IRS tax regulations and the 1 for 2 Trump executive order - March 1, 2017
Daniel Bunn
Daniel Bunn is Vice President of Global Projects at the Tax Foundation, where he researches international tax issues with a focus on tax policy in Europe.
Latest posts by Daniel Bunn (see all)
- A regulatory tax hike on US multinationals - February 28, 2022
- Can GILTI and the GloBE be harmonized in a Biden administration? - March 3, 2021
- The protectionism of Biden’s cross-border tax plan - September 15, 2020
Robert Feinschreiber
Latest posts by Robert Feinschreiber (see all)
- CIAT releases detailed proposals aimed at stopping transfer pricing abuse - July 17, 2019
- CIAT transfer pricing audit guide to aid member countries’ tax administrations - August 22, 2018
- CIAT preparing “sixth method” transfer pricing database - April 9, 2019
- CIAT-SECO partnership strengthens Latin American and Caribbean tax administrations - April 3, 2019
- The new OECD/G20 guidance aligning transfer pricing outcomes with value creation: upending international contract law - May 4, 2017
Sam Olchyk
Latest posts by Sam Olchyk (see all)
- US professors advocate international tax reform before Senate Finance panel - October 5, 2017
- US lawmakers stake out position on border adjustment tax - May 25, 2017
Greg Kidder
Latest posts by Greg Kidder (see all)
- Key takeaways from the proposed foreign tax credit regulations - December 19, 2018
Latest posts by Thomas Locher (see all)
- Global minimum tax could create confusion with current CFC rules - July 28, 2021
Latest posts by Richard Slowinski (see all)
- India-US bilateral advance pricing agreements and tax benefits for US multinationals - September 15, 2021
Latest posts by Alex Parker (see all)
- Muddled goals, broad scope lead to unexpected costs of OECD tax agreement - April 20, 2022
- White House’s hopes of an international tax revenue windfall may be overblown - October 29, 2021
- US Democrats’ hopes of overhauling TCJA’s foreign taxes stemmed by global pressure - September 27, 2021
Latest posts by Kyle Pomerleau (see all)