PRIVATE SECTOR EXPERIENCE

Current

  • Principal, Economics Partners – a Ryan Company, Denver office
    • Specializes in providing transfer pricing and business valuation services, with a focus on tax controversy and planning, to clients in a variety of industries, including agriculture, automotive, banking, biotech, chemicals, cement, computer products, distribution, food and beverage, healthcare, insurance, mining, oil and gas, pharmaceuticals, and software.
    • Twenty years of experience in applied economic consulting, including transfer pricing, complex valuation, lost profits and lost benefits (economic damages) analysis, and intangible asset pricing and valuation.

Previous

  • President and Founder, transfer pricing and business valuation firm
  • Managing Director, financial services firm
  • Vice President, international economics consulting firm
  • Partner, Big Four accounting firm

PUBLIC SECTOR EXPERIENCE

Previous

  • Adjunct Professor, Johns Hopkins University, Master of Business Administration (MBA) Program, Mergers, Acquisitions, and Valuation, Spring 2000

PUBLICATIONS

Published Papers

  • The Border Adjustment Tax: What Companies Need to Know, Tax Notes, March 2017 (with Perry Urken)
  • The Investor Model, World Finance, March 2009
  • Why Limited Risk Entities Should Earn Less Than The "Comparables" Earn: An Economically Accurate Approach to Profit Benchmarking for Limited Risk Entities Using Credit Default Swaps, Euromoney Corporate Tax Handbook, 2008
  • Valuing an Intangible Asset for Purposes of an Intercompany Transfer: How It Differs from Intangible Asset Valuation for Financial Statement Purposes, Transfer Pricing Insights, October 2007
  • Financial Statement Auditors and Transfer Pricing: A Practical Approach, Transfer Pricing Focus, Co-authored, Fall 2005
  • A Comment on Resale Minus Pricing, Transfer Pricing Report, February 16, 2005
  • Using Real Options to Transfer Price Research-Based Intangibles, Journal of International Taxation, May 2003
  • Observational Equivalence and Marketing Intangibles: The Problem of the Section 482 "Cheese Example," Transfer Pricing Report, September 1997

Policy Papers

  • What Is an Arm's Length Buy-in? An Economic Evaluation of the IRS' Investor Model and Coordinated Issue Paper, Policy Paper written on behalf of the Silicon Valley Tax Director's Group, December 2007
  • Profitability Measures, Working Capital Intensity, and Return on Capital Employed: Implications for Transfer Pricing Policy, Policy Paper for the Australian Tax Office, April 30, 1999 (with Clark Chandler, Ph.D.)
  • Australia's "Factor F" Policy: Implications for Transfer Pricing and the Pharmaceutical Industry, Policy Paper for the Australian Tax Office, August 15, 1998 (with Clark Chandler, Ph.D.)

Working Papers

  • How to Define and Value Goodwill, Economics Partners White Paper, March 2013
  • Capital Intensity and Margins: A Method for Analyzing Financial Comparability with Application to Distributors, Economics Partners White Paper, February 2013
  • On the Use (and Misuse) of Market Multiples: The Distinction between Direct and Indirect Market Multiples and Why it Matters, Economics Partners White Paper, January 2013
  • How to Accurately Price and Design Intercompany Debt, Economics Partners White Paper, February 2012
  • The Cost of Capital When Discounting Residual Profit: A Case Study, Economics Partners White Paper, January 2012
  • On the Meaning of Economic Life: An Overview and Proposed Method of Estimation, January 2011
  • What is the Incremental Cost of Capital from Taking on a Royalty Obligation: Or, the Risk Accounts for the Licensor-Licensee Profit Split, October 2010
  • Technology's Share of Operating Profit: What are the Implications of the Empirical Economics Literature? June 2010
  • Do Markets Reward Excess Working Capital? February 2010
  • What is an Arm's Length Buy-in? An Economic Evaluation of the IRS' Investor Model and Coordinated Issue Paper, and a Proposal for Moving Forward, October 2008
  • The Licensor-Licensee Profit Split: A Microeconomic Analysis, Co-authored with Ian Gray, August 2008
  • Estimating the Required Rate of Return to Intangible Property Investments, Co-authored with Ian Gray, April 2007
  • Creating CUPs: Using Experimental Economics and Laboratory Markets to Discover Arm's Length Prices, July 2005

PRESENTATIONS

  • The Border Adjustment Tax, International Fiscal Association USA Branch Annual Conference, February 2017
  • Profit Splits after BEPS, TP Minds USA Transfer Pricing Summit, February 2017
  • Transfer Pricing Design: Proper Use of Market Evidence, International Fiscal Association USA Branch Annual Conference, February 26, 2016
  • Transfer Pricing in the Pressure Cooker: The Final BEPS Reports on Action Items 8-10, Covington & Burling International Tax Conference, October 2015
  • Value Creation, National Association of Business Economists, Transfer Pricing Conference, July 2015
  • Post-acquisition Buy-ins, Tax Executives Institute/International Fiscal Association Conference, April 2014
  • Decomposing the Income Method: A Methodology for Determining the Forecast-implied Goodwill Contained in the Income Method, University of San Diego Tax Conference, March 2014
  • Intangibles: A Complex Evolution, International Fiscal Association Annual Meeting, San Francisco, California, March 2014
  • A Quantitative Approach to CPMs, Economics Partners Tax Law and Economics Seminar Series, December 2013
  • Intangible Assets – Definitions and Valuation, National Association of Business Economists, Transfer Pricing Conference, August 2013
  • Intangible Assets and Goodwill, Bloomberg/Bureau of National Affairs/Baker & McKenzie Transfer Pricing Conference, June 2013
  • Discount Rates, National Association of Business Economists, Transfer Pricing Conference, August 2012
  • The Realistically Available Alternatives Standard, Bloomberg/Bureau of National Affairs/Baker & McKenzie Transfer Pricing Conference, June 2012
  • The New Cost Sharing Regulations, Tax Executives Institute, International Transfer Pricing Seminar, April 20, 2007
  • International Bureau of Fiscal Documentation, Two-day seminar on Transfer Pricing, April 2006
  • Pharmaceutical Transfer Pricing: Profit Splitting and Marketing Intangibles, ATLAS Las Vegas Pharmaceutical Transfer Pricing Conference, March 2006
  • Real Option Pricing and Intellectual Property, ATLAS International Tax Conference, Chicago, May 12, 2003
  • Transfer Pricing – Planning and Compliance Considerations, International Tax Conference sponsored by Ernst & Young, Cleveland, March 19, 2003
  • The Role of Economists in International Tax Planning, CITE International Tax Conference, New York, March 10, 2003
  • Real Options and Pharmaceutical Transfer Pricing, ATLAS Life Sciences Conference, San Francisco, December 17, 2002
  • Supply Chain Management and Transfer Pricing for the Retail Sector, Ernst & Young Client Conference, December 10, 2002
  • Real Option Transactions and Pricing Methodologies, Internal Revenue Service Transfer Pricing Seminar, December 9, 2002
  • Transfer Pricing for Intellectual Property – Update, Akron University International Tax Conference, October 14, 2002
  • Transfer Pricing Trends – Issues and Opportunities, Cleveland Tax Club, September 16, 2002
  • Pricing Compounds as Options, Ernst & Young Health Sciences Conference, June 6, 2002
  • Real Options and Pharmaceutical Transfer Pricing, ATLAS Life Sciences Conference, San Francisco, May 13, 2002
  • Transfer Pricing in a New Era, Ernst & Young SALT Roundtable, July 18, 2001
  • Intangible Property Valuation, Ernst & Young, Manager/Senior Manager International Tax Update, 2001
  • Valuation of Closely-held Firms and Non-Market Intangibles, Cray Center for Entrepreneurship and the Economy, Occasional Lecture, Benedictine College, February 19, 2000
  • Valuation and Finance Principles Applied to Transfer Pricing, Internal Revenue Service and Treasury Department economists, September 11, 1997 (with Brian Becker, Ph.D.)

PUBLICLY FILED EXPERT REPORTS

  • Supreme Court of Newfoundland and Labrador, General Division. In re: Labrador Nickel Royalty Limited Partnership v. Vale Canada, et al. Case No. 2009 01T 4634. An Economic Analysis of Voisey's Bay's Controlled Sales of Nickel Concentrate to Vale Inco Compared to Vale Inco's Third Party Nickel Concentrate Sales and Purchases. Dated February 28, 2018.
  • Supreme Court of Newfoundland and Labrador, General Division. In re: Labrador Nickel Royalty Limited Partnership v. Vale Canada, et al. Case No. 2009 01T 4634. The Commercially Reasonable Nickel Concentrate Price for Nickel Concentrate Transfers from Voisey's Bay to Long Harbour. Dated March 2, 2018.
  • Supreme Court of Newfoundland and Labrador, General Division. In re: Labrador Nickel Royalty Limited Partnership v. Vale Canada, et al. Case No. 2009 01T 4634. Reply to the Reports of: Mr. Peter Searle, dated April 20, 2018 and Dr. Thomas Horst, dated April 14, 2018. Dated May 31, 2018.
  • Supreme Court of Newfoundland and Labrador, General Division. In re: Labrador Nickel Royalty Limited Partnership v. Vale Canada, et al. Case No. 2009 01T 4634. Reply to Reports of: Dr. Thomas Horst, dated April 24, 2018, Dr. Graham Davis, dated April 22, 2018, and Mr. John Donnelly, dated April 24, 2018. Dated June 11, 2018.
  • Ontario Superior Court of Justice (Commercial List), and United States Bankruptcy Court for the District of Delaware. In re: Nortel Networks, Inc., et al., Chapter 11, Case No. 09-10138 (KG) (Jointly Administered). Expert Report of Timothy A. Reichert. Dated January 24, 2014.
  • Ontario Superior Court of Justice (Commercial List), and United States Bankruptcy Court for the District of Delaware. In re: Nortel Networks, Inc., et al., Chapter 11, Case No. 09-10138 (KG) (Jointly Administered). Rebuttal Report of Timothy A. Reichert. Dated February 28, 2014.
  • United States Tax Court, Medtronic, Inc. and Consolidated Subsidiaries v. Commissioner of Internal Revenue. Docket No. 6944-11, Economic Analysis and Evaluation, Response to the Messrs. Lee, Berneman, and Kennelly. Dated December 3, 2014.
  • United States Tax Court, Zubair Kazi, et. al., v. Commissioner of Internal Revenue, Docket No. 20201-13, An Economic Assessment of the Management Services Payments from Kazi Foods Entities in the United States to Kazi Management VI, LLC in the U.S. Virgin Islands.

TESTIMONY EXPERIENCE

  • Deposition Testimony, Ontario Superior Court of Justice (Commercial List), and United States Bankruptcy Court for the District of Delaware. In re: Nortel Networks, Inc., et al., Chapter 11, Case No. 09-10138 (KG) (Jointly Administered).
  • Trial Testimony, Ontario Superior Court of Justice (Commercial List), and United States Bankruptcy Court for the District of Delaware. In re: Nortel Networks, Inc., et al., Chapter 11, Case No. 09-10138 (KG) (Jointly Administered), Allocation Trial.
  • Trial Testimony, Ontario Superior Court of Justice (Commercial List), and United States Bankruptcy Court for the District of Delaware. In re: Nortel Networks, Inc., et al., Chapter 11, Claims Trial.
  • Trial Testimony, Medtronic, Inc. and Consolidated Subsidiaries v. Commissioner of Internal Revenue, Docket No. 6944-11.
  • Deposition Testimony, BellSouth Telecommunications, LLC, formerly known as BellSouth Telecommunications, Inc., Petitioner, vs. Lynnette T. Riley, in her official capacity as Revenue Commissioner of the State of Georgia and Chairman of the State Board of Equalization, Respondent, Docket No. 1426716.
  • Appeals Testimony in Numerous Matters before IRS Appeals.

ARBITRATION EXPERIENCE

  • Arbitration Testimony and Negotiation, January–July 2016, Matter involving Large Technology Company and Israel Tax Authority

HONORS AND AWARDS

  • Departmental Scholarship, Department of Economics, George Mason University
  • Departmental Fellowship, The Catholic University of America
  • University Scholarship, Franciscan University
  • Recipient, Orestes Brownson Scholar Award, Franciscan University

EDUCATION/ACCREDITATION

  • Doctor of Philosophy Degree, Economics, George Mason University
  • Master of Arts Degree, International Political Economics, The Catholic University of America
  • Bachelor of Arts Degree, Political Philosophy, Cum Laude, Franciscan University
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