A Partner with White & Case, Brian Gleicher focuses on international tax issues with an emphasis on transfer pricing and tax treaty issues. He routinely represents multinational companies in transfer pricing matters, including advance pricing agreements, with the Internal Revenue Service and foreign tax authorities. He also advises taxpayers on proceedings before the US and foreign Competent Authorities on a broad range of issues, including double taxation, residency and permanent establishment questions.
Additionally, Mr. Gleicher represents corporate and individual taxpayers in domestic tax examinations and settlement negotiations with the Internal Revenue Service at the examination and appeals levels.
Mr. Gleicher is a member of the District of Columbia and Florida Bars and is admitted to practice before the US Tax Court. Active in the Federal Bar Association Section of Taxation, he is currently an officer and has served as the chair of the Section of Taxation as well as the Section's Annual Tax Law Conference. He is also a member of the Transfer Pricing Committee of the American Bar Association Section of Taxation.
J.D. Georgetown University Law Center (1995) cum laude
B.S., University of Florida, Fisher School of Accounting (1992) high honors
Bloomberg Tax Management Portfolios
Transfer Pricing: Competent Authority Consideration (Portfolio 6928)
DescriptionThis Portfolio also examines the costs and benefits of seeking a competent authority agreement.
Table of ContentsI. IntroductionII. Treaty Basis for Competent Authority Relief III. U.S. Implementation of the Competent Authority Procedure IV. Procedures for Requesting Competent Authority Assistance V. Limitations on Applicability and Availability of Competent Authority Relief VI. Considerations in Requesting Competent Authority Assistance VII. Negotiation of the Agreement Between the Competent Authorities VIII. Competent Authority Process in U.S.-Initiated Transfer Pricing Cases IX. Competent Authority Process in Foreign-Initiated Transfer Pricing Cases X. Finalization of Competent Authority Agreement XI. Direct Costs and Benefits of a Competent Authority Agreement XII. Indirect Costs and Benefits of a Competent Authority Agreement