Brian E. Andreoli is a partner at DLA Piper who focuses his practice on transfer pricing, international tax matters, and state tax matters. Mr. Andreoli has been a tax professional for more than 30 years, with experience in public, accounting, corporate (both foreign and domestic) law, and litigation. He has tried cases and administrative hearings in the states of New York, Connecticut, Ohio, California, Virginia, North Carolina, South Carolina, Pennsylvania and Washington.  These cases have concerned corporate income tax, sales and use tax, franchise tax and property tax. He also practices in voluntary disclosures for both corporations and individuals, concerning both civil and criminal penalties.  Mr. Andreoli is admitted before the bars in Connecticut, New York, Massachusetts, and the District of Columbia, and is a Certified Public Accountant. He is licensed to practice in the United States Tax Court, Second Circuit Court of Appeals, the United States Supreme Court, and the Federal District Courts of the District of Columbia, Connecticut, Massachusetts, and New York (Southern and Eastern). He has been listed in the 2008 Guide to the World's Leading Transfer Pricing Advisers.

Dr. Richard (Dick) Boykin is a principal economist in Baker & McKenzie's global transfer pricing group.  Dick’s experience in transfer pricing includes several substantial intercompany pricing dispute resolution cases; dozens of transfer price planning and documentation projects; and the valuation of intangible assets in the food, apparel, electronics, scientific instruments, hotel, restaurant, financial services, and software industries.  Richard is widely published in the transfer pricing field and regularly presents at conferences on the topic and related issues.   His most recently published article, co-authored with Antonio Russo of Baker & McKenzie's Amsterdam office, is entitled "OECD Developments on Comparability and Profit Methods," and appeared in Tax Planning International, Transfer Pricing, Vol. 9, No. 12, December 2008. 

Prior to assuming his role at Baker & McKenzie , Dr. Boykin held a variety of leadership and client service positions with one of the Big Four accounting firms, including global head of transfer pricing.  He also worked for a large economic consulting firm where he provided consulting services and expert testimony on price, cost, and labor market issues, and managed the econometric modeling and forecasting efforts for key products and engagements.  He taught graduate and undergraduate courses at the University of Maryland, including microeconomics, macroeconomics, industrial organization, time series statistical methods, and strategic planning. Dr Boykin has a Ph.D. in Economics from the University of Maryland where he also obtained Bachelor of Science and Bachelor of Arts degrees (summa cum laude).

Paul Chmiel is a member of Ernst & Young LLP’s National Transfer Pricing group located in New York and Iselin. Having been with the firm for more than ten years, he focuses on valuation in the pharmaceutical and distribution industries. He also has extensive experiences in dealing with several major telecommunication companies. 

Paul’s experience has been in the context of tax efficient intangible migration planning; resolution of tax audit controversies with the IRS at the field audit, appeals and competent authority levels; advance pricing agreements; cost sharing and intercompany service arrangements. Paul served 33 years at the Internal Revenue Service that included 28 years in the IRS’ New Jersey office international arena with a specific focus on the complex examination of the major pharmaceutical companies. He was the first transfer pricing issue specialist for the nation responsible for developing consistent transfer pricing positions throughout the US. He was also a representative on a team that wrote the 482 Regulations, including the proposed, temporary and final regulations. Paul participated in the most complex APA cases as a technical specialist and assisted in competent authority negotiations. Paul has a B.A. in Accounting from Seton Hall University.

Lucia Fedina is a Managing Director at KPMG LLP in New York.  Over the past 11 years, Lucia has providing transfer pricing advice in the New York area.  Lucia specializes in transactions that involve services and intangibles.  She has worked with clients in Financial services, Pharmaceutical, Chemical and other industries on projects related to planning, audit defense, APA, Fin 48 Reserves and documentation.    Currently, Lucia is a KPMG Global Coordinator for provision of Transfer Pricing services related to Investment Management. 

Examples of Lucia’s prior work include assisting clients in streamlining and simplification of their transfer pricing policies for intangibles and services transactions.  The new policies led to efficiency in implementation and significant reduction in yearend adjustments.  Lucia has participated in several restructuring projects where she assisted in aligning tax, business and transfer pricing objectives for the clients in luxury, consumer products, banking, insurance and other industries.  

While in graduate school, Lucia’s research was related to the analysis of exchange rates and present value models.  Lucia’s prior work experience includes 2 years as a chemical engineer (during which she obtained a patent for developing a new catalyst for oil refining) and 2 years as a biotech researcher.  Lucia holds a Ph.D. in Economics from Ohio State University.

Paul Flignor, Principal Economist with DLA Piper's Tax group based in Chicago, concentrates his practice in intercompany pricing and intellectual property valuation.  He has more than 15 years of professional experience in resolving pricing and valuation issues in the areas of international tax planning, controversy resolution, transaction support, licensing and financial economics.

He is noted particularly for integrating business strategy and financial economics to solve complex valuation problems of leading companies.  Mr. Flignor has worked extensively in the automotive, information services, software, consumer products and electronics industries. Over the years, he has successfully run transfer pricing and valuation projects for a variety of purposes, including:  Intercompany pricing, including audit defense, Advanced Pricing Agreements, cost sharing and intangible migration, and global documentation; Business valuation for both tax and financial reporting purposes, including purchase price allocation; Transaction support, including due diligence analysis and pre- and post merger integration planning; Intellectual property valuation and management.

Paul Mulvihill is a member of Ernst & Young’s Canadian Transfer Pricing practice and is based out of Ottawa, Canada. With more than 12 years of experience in transfer pricing, Paul focuses primarily on transfer pricing controversy, dispute resolution, and risk management. He is a member of Ernst & Young’s Global Transfer Pricing Controversy Network. 

Prior to joining the firm, Paul was the Advisor on Tax Dispute Resolution at the Organization for Economic Co-operation and Development’s (OECD) Center for Tax Policy and Administration in Paris, where he worked on various transfer pricing and tax treaty policy issues. Before moving to the OECD in April 2005, Paul was the manager of a Competent Authority Services Team in the International Tax Directorate of the Canada Revenue Agency. There he gained extensive experience in international tax controversy while managing advance pricing arrangements and mutual agreement procedure cases and developing policies on substantive transfer pricing issues. Paul spent the first five years of his Canadian public service career in various regional tax service offices and as an analyst with the Treasury Board Secretariat before moving to the International Tax Directorate in 1997. 

D. Clarke Norton is a principal economist in DLA Piper's Tax group and co-head of the Transfer Pricing practice. With nearly 20 years of experience, she is recognized as a leading authority on transfer pricing, dispute resolution and avoidance.  Ms. Norton comes to DLA Piper from Duff & Phelps, where she was co-leader of the Transfer Pricing practice. She and her team currently advise Fortune 500 companies on all aspects of transfer pricing, including APA and Competent Authority matters. As the foremost expert in transfer pricing for the apparel and footwear industries, Ms. Norton focuses her practice on consumer products and retail operations and has extensive experience in supply chain and procurement transfer pricing for multinational corporations. 

Ms. Norton has served as an expert economist to the US Attorney's Office and is a frequent speaker and author on transfer pricing, business planning and intellectual property.  International Tax Review has named her one of the World’s Leading Transfer Pricing Advisors.  Prior to working at Duff & Phelps in 2006, Ms. Norton founded and led the transfer pricing practice at FTI Consulting.  Before that, she was a partner at KPMG and a senior economist at NCR Corporation. She also served as the chief economist of the IRS Associate Chief Counsel's Advance Pricing Agreement Program, helping to negotiate hundreds of bilateral tax agreements with governments around the world.  Ms. Norton holds an M.P.I.A. in international management and finance and a B.A. in economics from the University of California at San Diego. 

Robert Plunkett is a principal in the New York office of Deloitte Tax LLP, and the leader of Deloitte Tax’s Financial Services Transfer Pricing Group.  He has served some of the firm's largest clients, including banks, investment banks, insurance companies, and investment advisors. 

Mr. Plunkett’s banking projects have involved income and expense allocation among branches for activities ranging from global trading to provision of ancillary/support services.  His investment banking experience includes analysis of global trading of derivatives, merger & acquisition activity, and loan syndication.  In global trading transactions, Mr. Plunkett has helped to price the assumption of market risk, the assumption of credit risk, the performance of trading functions, and the provision of sales/marketing services.  He has assisted insurance companies in pricing the transfer of risk among entities, and has worked on a number of investment advisory projects, including the pricing of advisory functions, subadvisory functions, custody functions, and brokerage functions.     

Brian Trauman is a partner and tax lawyer at Mayer Brown LLP whose practice is focused primarily on federal and international tax controversies. In this context, Brian has directed and managed enterprises’ transfer pricing strategies, compliance and controversies through coordination of parent companies and their worldwide affiliates in a variety of industries and functions. His experience with controversies includes audits, administrative appeals and litigation in subject matters ranging from Subpart F to leasing to promoter audits to transfer pricing. In addition, he has successfully lobbied Congress, the IRS and the US Treasury for changes to income tax laws and guidance. 

Brian has particularly significant experience in advising on supply chain organization and tax efficiency, as well as on direct and indirect tax and transfer pricing consequences of various functions including manufacturing, distribution, logistics and services. Brian has worked with revenue authorities and industry participants in North and South America, Europe, Asia, Africa and Australia to obtain successful resolution of controversies, including mutual agreement procedures, advance pricing agreements and rulings.  Brian joined the Washington, DC office of Mayer Brown in 2002, and subsequently moved to the firm’s New York office in 2004. Previously (2000-2002), he served as Law Clerk for The Honorable L. Paige Marvel, United States Tax Court, Washington, DC. Brian was recently recognized in International Tax Review, World Tax 2009 by a tax director as having "excellent judgment and knowledge in transfer pricing."  

Steven C. Wrappe is in Ernst & Young LLP’s International Tax Services Transfer Pricing practice. Steve is located in Washington, D.C. He brings over nearly 30 years of tax experience, including nearly 20 years of extensive experience in all aspects of transfer pricing across all industries. Steve’s knowledge in transfer pricing controversy includes examination, appeals, alternative dispute resolutions, advance pricing agreements, mutual agreement procedures and customs agreements. His combined advance pricing agreements and mutual agreement procedures experience is in excess of 100 cases.  Previously, Steve was a partner at a global law firm. 

Prior to that, he spent 10 years as a partner and director of the advance pricing agreement practice at another Big Four firm. Steve also brings a wealth of government experience to Ernst & Young, having served as an attorney at the Internal Revenue Service Office of Associate Chief Counsel (International) Advance Pricing Agreement Program.  Steve is actively involved in the international tax and transfer pricing community. He has served as Chair of the Transfer Pricing Committee of the American Bar Association’s Tax Section. He serves on the Board of Advisors of New York University School of Law’s International Tax Program and BNA Tax Management (Transfer Pricing). Steve is an Adjunct Professor (Transfer Pricing) at Georgetown University Law Center and New York University School of Law. He has published a leading transfer pricing treatise and over 100 articles on transfer pricing topics. Steve speaks globally on transfer pricing and dispute resolution. 

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