PRIVATE SECTOR EXPERIENCE

Current

  • Principal, Economics Partners – a Ryan Company, Washington, D.C. office
    • More than 15 years of experience in transfer pricing matters, intangible asset valuations, and other complex corporate valuations.
    • Designs, plans, and executes transfer pricing documentation strategies, particularly during periods of business reorganizations.
    • Advises on pricing intercompany intangible transfers, as well as establishes research and development (R&D) cost-sharing arrangements.

Previous

  • Partner, transfer pricing and business valuation firm
    • Advised or represented clients during Internal Revenue Service (IRS) tax audits, foreign tax audits, IRS fast-track negotiations, competent authority negotiations, and advanced pricing arrangement (APA) negotiations.
  • Founding Partner, transfer pricing and advisory firm
  • Vice President, global consulting firm
  • Partner, transfer pricing consulting accounting firm
  • Senior Manager, Transfer Pricing, Big Four accounting firm
  • Senior Consultant, Transfer Pricing, Big Four accounting firm

PUBLIC SECTOR EXPERIENCE

Previous

  • Research Analyst, International Monetary Fund

PUBLICATIONS

Mr. Cole has authored various papers on:

  • Canadian business taxation
  • Canadian public debt management
  • U.S. income distribution

Papers

  • Valuing Intangibles under Cost Sharing Arrangements, Tax Director’s Guide to International Transfer Pricing, Edited by Kenneth R.L. Parker, April 10, 2008
  • A Residual DCF Approach to Valuing Forgone Profits, BNA Tax Management Transfer Pricing Report, May 25, 2005
  • How you can combine risk and the arm’s length standard, International Tax Review’s Regional Guides, No. 5, North America, 2005
  • Adjusting for Differences in Risk Levels Between Tested Parties and Comparable Firms, BNA Tax Management Transfer Pricing Report, May 14, 2003
  • Medicare: Financial Problems and Reform Options, United States-Selected Issues, International Monetary Fund (SM/97/97), July 1997
  • Business Taxation in Canada, Canada-Selected Issues, International Monetary Fund (SM/97/20), January 1997
  • Income Distribution and Macroeconomic Performance in the United States, International Monetary Fund Working Paper Series (WP/96/97), August 1996
  • Federal and Provincial Debt and Debt Management Strategies, Canada-Selected Issues, International Monetary Fund (SM/96/96), March 1996

EDUCATION/ACCREDITATION

  • Master of Science Degree, Economics (Emphasis in Finance), University of Delaware
  • Bachelor of Science Degree, Math and Economics, Ithaca College
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