Cynthia Hustad was the Director (Retired) of the Northern California/Pacific Northwest Tax Controversy Services practice for Deloitte and represents corporate clients before the IRS. During her ten-year tenure at Deloitte, Cindy has successfully represented many large and small clients, both at the examination and appeals levels. Prior to joining Deloitte, Cindy was an attorney with the IRS Chief Counsel’s Office for 12 years where she represented the IRS in U.S. Tax Court in over 50 litigated cases.
During her period at the IRS, Cindy also advised large case agents, international examiners, and appeals officers in some of the largest examinations undertaken by the IRS involving a wide range of complex international and domestic corporate issues. Cindy also has represented the government in litigating several large corporate tax and transfer pricing cases, including DHL v. Commissioner.
Positions Held: Special Trial Attorney – IRS Chief Counsel – San Francisco, Acting Assistant Professor – New York University Law School, Law Clerk – United States Court of Appeals for the Ninth Circuit
Education:
LL.M., New York University Law School
J.D., University of Wisconsin Law School
B.A., University of Wisconsin
Tax Management Portfolios™
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Transfer Pricing: Audits, Appeals, and Penalties (Portfolio 6924)
This Portfolio analyzes transfer pricing recordkeeping requirements; audits, appeals, and penalties; document requests and summonses; and Competent Authority consideration in transfer pricing cases.