Director, Transfer Pricing
Ms. Amerkhail has more than 30 years of transfer pricing experience. She has worked closely on transfer pricing issues with international tax attorneys from many of the leading U.S. law firms, participating in negotiations involving all stages of IRS field examinations and appeals, and in Advanced Pricing Agreement (“APA”) negotiations with both the IRS and the Japanese National Tax Administration. Her economic reports have been used for all stages of transfer pricing planning and documentation, for the defense of transfer prices during both IRS and foreign tax authorities’ examinations, and for dispute resolution, including appeals, competent authority, and APAs.
In the preparation of transfer pricing plans, documentation reports, or APA proposals, Ms. Amerkhail has worked closely with clients and their attorneys to develop transfer pricing methodologies that are appropriate from a business perspective as well as acceptable to tax authorities. Her reports have covered both inbound and outbound distributors of a wide range of consumer and industrial products, providers of a many different types of services, and transfers of a wide variety of intangibles. In negotiations with the IRS, whether for APAs or at the examination or appeals levels, she has been involved in all stages of the negotiations, either cooperating with the IRS economist to reach conclusions acceptable to both sides, or demonstrating the unreasonableness of the IRS economist’s positions for the benefit of the rest of the IRS team.
Ms. Amerkhail was a participant in Transfer Pricing Experts Meetings sponsored by the Organization for Economic Cooperation and Development (“OECD”) in Paris in 2003 and 2004, in the OECD’s Centre for Tax Policy and Administration (“CTPA”) Roundtable on Business Restructuring in 2005. During July 2007 she participated as a lecturer in an OECD transfer pricing seminar for the Israeli Ministry of Finance and the Israeli Tax Authority, and in May 2009 she spoke on transfer pricing at the OECD’s International Seminar for Tax Judges in Paris.
Ms. Amerkhail is a former president of the Society of Government Economists, and of the National Economists Club.