Sam Maruca has practiced broadly and exclusively in the area of federal income tax since 1983, focusing in recent years on large-case controversies, including complex transfer pricing disputes. He has represented both US and foreign-based multinational companies in the pharmaceutical, bio-tech, communications, heavy manufacturing, entertainment, and retail sectors, in matters at the audit level, in IRS Appeals, in mediation, in competent authority, and in the courts. His expertise includes the preparation of opinion letters and compliance advice relating to cross-border financing transactions and transfer pricing matters, repatriation of foreign earnings, anti-deferral regimes and limitation on benefits, mutual assistance and other treaty issues.
From 2011-2014, Mr. Maruca served as the first Director of Transfer Pricing Operations in the Large Business & International Division of the Internal Revenue Service, where he had national responsibility for transfer pricing compliance and double tax cases under US tax treaties.
Education:
J.D., Georgetown University (1982)
B.A. Yale University (1977)
Tax Management Portfolios™
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Transfer Pricing: The Code, the Regulations and Selected Case Law (Portfolio 886)
This Portfolio is the foundation of the Transfer Pricing Portfolio Series.
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Transfer Pricing: OECD Transfer Pricing Rules and Guidelines (Portfolio 6936)
This Portfolio describes and interprets the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations of the Organization for Economic Cooperation and Development (OECD), as last revised in 2010.