Mark Nehoray, Deloitte US, is a Senior Partner in the Los Angeles office. He is a founding member of Deloitte's national transfer pricing practice in March 1990, as well as the founding member of its Los Angeles transfer pricing practice.
He has been consistently recognized by International Tax Review as one of the leading transfer pricing advisers in the United States and by Euromoney/Legal Media Group for inclusion in the Guide to the World's Leading Transfer Pricing Advisers, as well as one of The Best of the Best Transfer Pricing Advisers in the US and the World. He has also been included in International Tax Review's Guide to Tax Controversy Leaders (2014, 2015, 2016 & 2017).
Mark has over 36 years of public accounting and private industry experience, primarily in the international tax and transfer pricing areas. He consults with multinational clients on transborder transactions, assists multinational companies with transfer pricing studies, and consults with clients on restructuring of foreign royalties and other foreign income streams.
Mark is the transfer pricing advisor to four of the world's largest multinationals, and since 1990 has conducted a significant number of transfer pricing studies in a variety of industries (including media and entertainment, gaming, hi-tech, e-commerce, and nonprofit). These projects have included both defensive work with respect to ongoing tax authority audits and competent authority assistance, as well as planning studies and APAs. Some of these projects have involved tax planning involving licensing strategies and cost sharing arrangements. Over the past two decades he has been responsible for Deloitte's largest APAs. He is currently assisting two US-based multinationals with respect to their unilateral APAs, as well as assisting ten foreign-based multinationals with respect to their bilateral APAs.
Since 2002, Mark has been the executive producer and host of Deloitte's Transfer Pricing Dbriefs, a monthly Internet webcast program. He is a frequent speaker at US transfer pricing conferences sponsored by BNA.
Mark's recent publications include:
- OECD Guidance on Transfer Pricing Documentation: Preparing for the New Global Standard," Tax Management Transfer Report, Bloomberg BNA (26 May 2016)
- Complying with OECD's Country-by-Country Reporting," Anaplan (November 2014)
- Bachelor's Degree in Business Administration–University of Southern California
- Master's Degree in Business Taxation–University of Southern California