Valerie Amerkhail joined Economic Consulting Services, LLC in 1998, after almost twelve years of transfer pricing experience in Big 6 accounting firms, most recently as a partner at Coopers & Lybrand L.L.P.
Ms. Amerkhail has worked closely on transfer pricing issues with international tax attorneys from many of the leading U.S. law firms. She has participated in negotiations involving all stages of IRS field examinations, appeals, and Advanced Pricing Agreement (“APA”) procedures. Her economic reports have been used for all stages of transfer pricing planning and documentation, for the defense of transfer prices during examinations by both IRS and foreign tax authorities, and for dispute resolution, including appeals, competent authority, and APA negotiations.
Transfer pricing documentation reports produced under Ms Amerkhail’s supervision have covered both inbound and outbound distributors of a wide range of consumer and industrial products, providers of many different types of services, and transfers of a variety of intangibles. Ms Amerkhail successfully defended the first of these reports to come under examination by persuading the IRS field team to accept the report's definition of the scope of the controlled transactions, selection of the best method, choice of comparables, and adjustments to comparables, leaving only a small adjustment for the client's allocation of expenses between the controlled and uncontrolled transactions. A documentation report for another client was the substantive basis for an IRS economist’s “no change” recommendation, despite a history of contentious audits and large proposed adjustments in previous examination cycles.
B.A., Swarthmore College
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.