Joe Tobin is a Senior Manager in Global Transfer Pricing at Deloitte's Washington National Tax Practice. Joe is a world-renowned expert in transfer pricing controversy and transfer pricing planning, especially in the area of cost sharing arrangements. Joe serves a wide variety of clients, specializing in intangible-centric industries such as the high-technology industry and the bio-pharmaceutical industry. Joe was the primary drafter of the US Treas. Reg. §1.482-7 (2011) Final Cost Sharing Regulations and the US Treas. Reg. §1.482-7 (2013) Final Cost Sharing Regulations. Joe was chosen by USCIB to comment on the OECD's 2015 Discussion Draft on Cost Contribution Arrangements. Joe also helped the ABA and USCIB draft comments on Notice 2015-54 and the Section 367 temporary regulations and Section 482 temporary regulations released in September 2015.
Joe was previously Senior Counsel at the I.R.S. Office of Associate Chief Counsel (International) (Branch 6) (Transfer Pricing) in Washington D.C., where he was a reviewer for several high profile transfer pricing litigation cases, including VERITAS, Medtronic, Amazon, and BMC Software. Joe also advised I.R.S. Exam and Field Counsel on hundreds of contentious transfer pricing audits that went to I.R.S. Appeals. Joe was also commented on several versions of the draft I.R.S. Appeals Settlement Guidelines on Cost Sharing Buy-Ins, which have never been published. Joe was also known as the "go to" person for Advanced Pricing Agreements (APAs) with complex technical issues involving cost sharing arrangements (CSAs), and he advised on several such APAs with CSAs.
Joe has spoken at numerous conferences, webcasts, and training sessions on transfer pricing and cost sharing. He has been a member of the Georgetown Law Adjunct Faculty since 2013, where he co-teaches a class on transfer pricing.
Joe received a Masters Degree in Tax Law from New York University in 2007, a JD from the University of Virginia in 2005, and a Bachelor of Arts in Philosophy and Political Science from Reed College in 1995. Joe is licensed to practice law in Nevada and New York. Joe served in the US Army from 1997 to 2005 and was deployed several times, including deployments to Bosnia-Herzegovina and Cuba.