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Howard Berger

Special Counsel

Washington +1 202 662 5065

  • About
  • Representative Matters
  • Credentials
  • About

    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. Howard 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, Howard was a principal author of U.S. transfer pricing regulations.

    Howard also was with the national and London offices of a Big Four accounting firm and was international tax planning director for a Fortune 500 corporation.

    Areas of Expertise

  • Practices and Industries
  • Representative Matters
    • 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.

    Areas of Expertise

  • Credentials
    Education
    • University of Wisconsin Law School, J.D., 1980
        • cum laude
        • Order of the Coif
    • Bucknell University, B.A., 1971
    • University of Wisconsin, M.S., 1975
    Bar Admissions
    • District of Columbia
    • U.S. Tax Court
    Government Experience
    • U.S. Department of the Treasury – Internal Revenue Service
    Judicial Clerkship
    • Hon. Charles E. Clapp, U.S. Tax Court, 1983 - 1984
    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)

    Areas of Expertise

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