Philip Carmichael is a Principal Economist in Baker & McKenzie's New York office. He has advised several US-based companies on global transfer pricing including transfer pricing analysis, planning, documentation and dispute resolution. He has also coordinated and prepared documentation to serve the needs of tax authorities across different jurisdictions.
Mr. Carmichael advises clients on a wide range of matters including restructuring intercompany arrangements for tax planning, preparing US and foreign documentation, valuing intangible assets and audit defense. He has led numerous important engagements for clients in which licensing, cost-sharing and/or intellectual property migration have been a central strategy. His work spans a number of industries, including business products, industrial products, luxury goods, software and technology.
Education:
M.B.A., Georgetown University (1989)
B.A., University of Notre Dame (1984)
Tax Management Portfolios™
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Transfer Pricing: A Case Study (Methods and Documentation) (Portfolio 6912)
This Portfolio uses a case study involving a fictional company to provide a practical background on how to prepare a transfer pricing study to meet the regulatory and administrative documentation requirements in the United States and under the OECD Guidelines.