- Obtained numerous unilateral and bilateral advance pricing agreements (APAs) involving the IRS and other tax authorities.
- Resolved novel transfer-pricing issues such as using foreign parent company segment data as the tested party for an APA, intangible property migration, foreign currency fluctuations, financing transactions and guaranties, plant startup and shutdown situations, U.S. domestic transfer pricing, and customs implications.
- Secured favorable competent authority agreements to eliminate double taxation in controversies involving, for example, the U.S., Australia, Canada, China, France, Germany, Japan, Mexico, Switzerland, and UK.
- Advised numerous multinational companies in the motor vehicle, aerospace, telecommunications, hospitality, finance, and other industries on tax-efficient supply chain restructurings, including cash pooling systems, involving Europe, Asia, and the Americas.
- Advised various multinational companies on intangible property migration strategies and compliance.
- Counseled a pharmaceutical company on strategies to address transfer-pricing risks and reduce taxable permanent establishment concerns.
- Advised multinational companies on the tax and customs implications of cross-border transactions.
- Advised a tax-exempt organization on tax issues associated with transactions involving taxable affiliates.
Partner,
- Phone: 202.239.3231
- Email: richard.slowinski@alston.com
Richard’s multinational clients benefit from his extensive experience with tax planning and controversy and trust his guidance to resolve challenging transfer-pricing issues as well as to develop, implement, and defend tax-efficient cross-border structures.