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Matthew Kramer

 

 

 

Executive summary


Matt is based in San Francisco and is a Transfer Pricing Managing Director for the Greater Bay Area and the West Region.

Matt advises clients on all aspects of transfer pricing, including planning, mutual agreement procedure filings, advance pricing agreements, audit defense, IRS Appeals, and litigation. Matt has extensive experience in several transactional areas, including cost sharing arrangements, platform contribution transactions, licensing, business restructurings, captive insurance, manufacturing, distribution, research and development services, and headquarters services.

In addition to transfer pricing, Matt has advised clients on other complex international and federal tax law issues. Projects include stock options in cost sharing arrangements; foreign tax credits; source and character of income issues, including those arising in electronic commerce and cloud computing transactions; and section 367(d) issues.

Matt’s experience includes 11 years as team leader and Special Counsel in the Internal Revenue Service’s Advance Pricing Agreement Program in San Francisco and, prior to joining Grant Thornton, five years in a major U.S. law firm. While in the IRS, Matt negotiated advance pricing agreements between foreign governments, multinational corporations and the IRS, with special emphasis on intangible property transfers, the provision of services, and high technology companies. He also revised APA revenue procedures and developed guidelines for IRS field personnel for resolving transfer pricing audit disputes.

Matt’s law firm experience includes extensive APA and transfer pricing planning, controversy, and litigation work.

 

Professional qualifications and memberships

  • California State Bar
     

Education

  • J.D. and Ph.D., University of California, Berkeley
  • M.A., Indiana University
  • B.A., University of Michigan



 
 

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