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Howard Berger advises clients on transfer pricing, other international tax issues, and tax controversy. His practical perspective is based on more than thirty years of experience. He recently served as Senior Adviser to the Director of Transfer Pricing Operations at the Internal Revenue Service, where he represented the IRS in examinations and before Appeals, and developed cases for litigation. Mr. Berger also was the primary U.S. representative in arbitration proceedings under U.S. tax treaties and represented the U.S. in Competent Authority negotiations. In previous service with the IRS, Mr. Berger was a principal author of U.S. transfer pricing regulations.

  • Advising a foreign corporation on structuring a foreign partnership between a U.S. affiliate and a foreign affiliate and transferring property to the partnership in a tax efficient manner.
  • Representing a U.S. corporation in obtaining a bilateral Advance Pricing Agreement.
  • Representing a U.S. corporation in an examination by the Internal Revenue Service of transfer pricing and other international tax issues.
  • Advising a U.S. corporation on structuring a cost sharing arrangement with a foreign affiliate.

Previous Experience

  • Internal Revenue Service, Senior Adviser to the Director of Transfer Pricing Operations
  • Internal Revenue Service, Special Counsel to the Assistant Chief Counsel (International)