Darrin Litsky, Deloitte US, is trained as a lawyer and is a Certified Public Accountant. He is also a transfer pricing specialist in Deloitte's New York office. Darrin has a diverse background of 30 years of professional tax and accounting experience with industry, Big Four public accounting, major law firm, and the Internal Revenue Service's (IRS) advance pricing agreement (APA) programme. While in industry, Darrin served as General Tax Counsel of a publicly owned telecommunications company and was responsible for its worldwide transfer pricing in over 40 countries.
Darrin served as a Team Leader for four years with the IRS APA Program. Including his time in government practice, Darrin has been substantively involved in hundreds of APA and mutual agreement procedure (MAP) requests involving a variety of different countries and industries. His current transfer pricing practice is primarily APA and MAP request representations and audit defense.
Darrin is a past Chairman of the Transfer Pricing Committee of the American Bar Association (ABA) Tax Section.
In 2014, Darrin led a ABA task force that provided formal comments to the IRS on proposed procedures for obtaining an APA. Similarly, in 2005, Darrin was responsible for leading the ABA's formal comments to the IRS on the operation of the APA Program. As part of this effort, he provided oral testimony on the APA Program in a public hearing held in Washington.
In 2004, Darrin led another ABA task force that provided formal comments on proposed Treasury Regulations for transfer pricing of intercompany services. In 2006, Darrin contributed to the ABA's comments on temporary Treasury Regulations for transfer pricing of intercompany services.
Recent Articles and Publications
- "Strategic Considerations for Tax Controversy Risk Management and Double Taxation Avoidance," International Tax Review (March 2016) (with S. Kumar and E. Lesprit).
- "Comments on Notice 2013-79 Proposed Procedures for Advance Pricing Agreements," http://www.americanbar.org/content/dam/aba/ administrative/taxation/policy/031814comments.authcheckdam.pdf (March 18, 2014) (with ABA members).
Recent Speeches and Presentations
Darrin has given numerous speeches and presentations over the years at the American Bar Association, the American Conference Institute, New York University, Tax Executive Institute, Broadband Tax Institute, CITE, ATLAS, and at IRS meetings and conferences on transfer pricing issues and advance pricing agreements including the following:
- Moderator, Insurance and Reinsurance Transfer Pricing, American Bar Association Tax Section (May 2017)
- Advance Pricing & Mutual Agreement Procedures, American Bar Association Tax Section (May 2015)
- Juris Doctor, Georgetown University Law Center, 1993
- BS Economics, magna cum laude, The Wharton School, University of Pennsylvania, 1986