Steven C Wrappe is KPMG's Deputy Head of Global Transfer Pricing Dispute Resolution.
Professional and Industry Experience
Steve has over 25 years of transfer pricing experience. Prior to KPMG, he led the APA practice at two other Big Four Firms, was a partner with a global law firm, and was a Senior Attorney with the IRS APA Program. His transfer pricing controversy experience includes examination, appeals, alternative dispute resolutions, advance pricing agreement (APAs), mutual agreement procedures (MAP) and Customs agreements.
Steve is the most experienced APA negotiator at any firm, with the experience of nearly 200 cases. He has negotiated APAs in the following industries: automotive, automotive parts, aero engines, beverages, chemicals, construction equipment, data processing, electronics, fast moving consumer goods, food, food service, health products, motorcycles, musical instruments, pharmaceuticals, and photographic equipment.
Publications and Speaking Engagements
Steve has published the fourth edition of his leading U.S. transfer pricing treatise: Transfer Pricing: Rules, Compliance and Controversy (Wolters Kluwer/CCH, 2013) (with Marc Levey) and written more than 100 articles on transfer pricing topics, including:
- Recent Changes in the United States APA Process Have a Positive Impact on US-Japan APAs, 26 Tax Mgt. Transfer Pricing Report 486, 9/21/17 (with Yuri Numata).
- Do Advance Pricing Agreements Still Make Sense?, 24 Tax Mgt. Transfer Pricing Report 976, 11/24/15.
- It Ain't Over Till It's Over: Federal Tax Implications of Implementing a Sustained Transfer Pricing Adjustment, 23 Tax Mgt. Transfer Pricing Special Report, 872, 10/29/14 (with Erin Collins and Cameron Taheri).
- The Best Transfer Pricing Defense is a Good Offense: Get a Bilateral U.S. APA to Benchmark Results, 23 Tax Mgt. Transfer Pricing Report 629, 9/2/14 (with Koichiro Fujimori).
- Transfer Pricing and Customs Valuation: The Growing Need for Harmonization, Tax Mgt. Transfer Pricing Special Report, Vol. 17, No. 8 (August 28, 2008)(with William Methenitis).
Steve has spoken at many leading global tax forums for the following groups: Organization for Economic Cooperation and Development, United Nations, International Fiscal Association, George Washington/IRS Tax Conference, Tax Executives national and regional meetings, World Customs Organization, American Bar Association, NYU Institute, and Practicing Law Institute.
Steve is an adjunct faculty at New York University School of Law. He has also taught transfer pricing at Georgetown University Law Center, University of Florida School of Law, IRS, U.S. Customs and several other tax authorities. Steve previously served as Chair of the Transfer Pricing Committee of the American Bar Association’s Tax Section.
New York University School of Law, LLM; University of Texas School of Law, JDUniversity of Notre Dame, BBA (Accounting)