Is the OECD Inclusive Framework Digital Project the Beginning of the End of the Arm’s Length Standard?This is not the end. It is not even the beginning of the end. But it is, perhaps, the end of the beginning.”
Mike Patton is a partner in DLA Piper's Tax practice, based in Los Angeles. He focuses his practice on international transfer pricing.
Mr Patton has assisted many multinational corporations in a variety of industries in resolving IRS or foreign tax authority transfer pricing and other tax disputes as well as in planning major cross-border transactions. He was instrumental in obtaining the world's first Advance Pricing Agreement and he has assisted clients in negotiating more than 100 APAs.
Mr Patton was previously an attorney in the IRS Chief Counsel's Office where he had national responsibility at IRS for technical issues, regulations and litigation of cases relating to transfer pricing. Mr Patton was editor of and a major contributor to the Treasury/IRS Transfer Pricing White Paper. The White Paper laid the theoretical ground work for the profit-based transfer pricing methods adopted by the US and the OECD.
Mr Patton has been named one of the Best of the Best US transfer pricing advisors as well as one of the leading Asia Pacific tax advisors by Euromoney and the Legal Media Group. He is an editorial advisory board member of Tax Management, Inc. and is the author of the BNA portfolio Treatment of Advance Pricing Agreements.
University of Maryland J.D. with honorsOrder of the CoifGeorgetown University Law Center LL.M.University of Maryland B.A.
On July 19 2013, the Committee on Fiscal Affairs (CFA) of the OECD published its action plan to address base erosion and profit shifting (BEPS). The action plan follows from directives given to the CFA by the G20 group of countries to better address global corporate taxation and builds upon the...
Transfer pricing (what related companies charge each other for goods, services, financing or use of IP) has traditionally been a well-established source of tax planning opportunity for multi-national enterprises ("MNEs"), large and small. However, over the last year, transfer pricing has...