Jerrie Mirga joined Economic Consulting Services in 1986 as an Economist. She became Senior Economist in 1987, and in 1997 she became Director, Transfer Pricing and Customs. In her current position as Vice President, she works with clients in a wide range of industries, predominantly in the areas of international transfer pricing and the valuation of businesses and intangibles.
Ms. Mirga has worked extensively on many of ECS’ projects in the transfer pricing area. She is responsible for developing the data needed to derive arm’s length intercompany prices and for conducting thorough analyses of company financial information. Her work in this area has involved the valuation of intangible property, which has included the study of numerous trademark and technology licensing agreements, as well as the valuation of tangible property and services. Her work has included projects that evaluated whether intercompany transfer prices were consistent with arm’s length expectations in cases where companies had undertaken a significant restructuring of their international operations. Other projects have involved determining buy-in payments for technology contributed to intercompany cost sharing arrangements, as well as analyzing the basis for sharing future development costs.
Ms. Mirga directs many of ECS’ transfer pricing documentation studies that taxpayers must prepare in order to fulfill the requirements of IRC Section 6662 regulations. She has also prepared non-US transfer pricing documentation studies designed to comply with the requirements of foreign tax authorities (e.g., Canada, Mexico) and the guidelines of the Organization for Economic Cooperation and Development. In addition, she has prepared written reports for use by taxpayers, the Internal Revenue Service, and foreign tax authorities at the audit stage, the litigation stage, and in support of Advance Pricing Agreements. She has worked with clients in many industries, including pharmaceuticals, medical equipment, food and beverages, oilfield services, semiconductors, and consumer electronics.
Ms. Mirga advises clients on Customs issues, including the classification of goods under the Harmonized Tariff Schedules (HTS) and obtaining statistical breakouts within the HTS, formulating responses to Customs Form 29 requests, requesting rulings from the Customs Service, filing protests, and developing arguments and strategies in connection with Section 516 protests and Court of International Trade proceedings. Her work in this area includes the valuation issues that can arise in transactions between related parties.
Additionally, Ms. Mirga has assisted clients with respect to their international trade policies. She has been responsible for the preparation of analyses and statements in connection with proceedings before U.S. trade agencies and the Congress. Much of this work has been for associations in the footwear, luggage and leather goods, and textile and apparel industries. She has also provided economic analysis in connection with trade litigation (i.e., antidumping) cases.
Before coming to ECS, Ms. Mirga was the Manager of Research in the International Trade and Economics Department of the American Iron and Steel Institute (AISI). At AISI, Ms. Mirga was the staff representative for a monitoring committee that provided the chief means of communicating industry concerns about the President’s Steel Program to government officials. She also performed statistical analyses and managed research projects in support of the industry’s trade policy positions. Prior to her employment at AISI, Ms. Mirga was a French teacher in the Williamsburg-James City County (Virginia) public schools.
M.B.A., International Business, George Washington University
B.A., College of William and Mary
Bloomberg Tax Management Portfolios
This Portfolio examines the availability of potential U.S. and non-U.S. external comparables that might be used to apply transfer pricing methods that depend on external comparables, including an analysis of the ranges of markups that are observed for generic sets of providers of various types of services.