Practical Guide to U.S. Transfer Pricing

Robert T. Cole (Original Author).  In 1997 Mr. Cole founded Alston & Bird's International Tax Group and practiced in that firm from 1997 to July 2012. In August 2012 he joined the Internal Revenue Service's Office of Transfer Pricing Operations. Mr. Cole served in the U.S. Treasury from 1967 to 1973 and was appointed as the first International Tax Counsel in 1971. Mr. Cole received his LL.B in 1956 from Harvard Law School and his B.S. in 1953 from the Wharton School of Finance, University of Pennsylvania, and an academic postgraduate diploma in law in 1959 from the London School of Economics. He was a member of the Council of the USA branch of the International Fiscal Association, a past vice-chair of the Tax Committee of the National Foreign Trade Council, and was a member of the Tax Section of the American Bar Association.

William H. Byrnes (principal author), an Executive Professor of Texas A&M University School of Law, is an author of nine LexisNexis international tax and federal tax treatises, three Tax Facts books of National Underwriter, and over 1,000 tax articles. In 1994, he developed an international tax graduate program, pioneering in 1998 the first online LL.M. offered by an ABA law school (International Taxation). He held a senior position of international tax at Coopers & Lybrand (South Africa) specializing in transfer pricing and functional analysis. Professor Byrnes undertook a three-year transfer pricing fellowship at the IBFD in conjunction with an LL.M. at the University of Amsterdam. His Lexis treatises include Taxation of Intellectual Property and Technology; Practical Guide to U.S. Transfer Pricing; Foreign Tax and Trade Briefs; Guide to FATCA Compliance; Money Laundering, Asset Forfeiture and Recovery, and Compliance; Tax Havens of the World; Federal Taxation of Oil & Gas Transactions; Texas Estate Planning; and International Withholding Tax Guide. He may be contacted at williambyrnes@gmail.com.