Principal, International Tax, Income Tax
PRIVATE SECTOR EXPERIENCE
- Principal, Economics Partners – a Ryan Company, Denver office
- Specializes in providing transfer pricing, business and intangible property valuation, and other tax and valuation-related projects to clients in a variety of industries, including automotive, chemicals, computer products, consumer durables, consumer non-durables, distribution, financial services, food and beverage, healthcare, insurance, medical devices, mining, oil and gas, pharmaceuticals, primary metals, software, and semiconductor.
- More than 15 years of experience in economic consulting, including pricing, valuation of complex securities, intangible asset pricing and valuation, and business valuation.
- Partner, transfer pricing and business valuation firm
- Handled issues involving the transfer of tangible and intangible property, technology buy-ins, cost sharing agreements, and the calculation of royalty rates to be paid between related parties. His research has been used to prepare advanced pricing agreements, transfer pricing documentation in the United States, Canada, and throughout Europe and Asia, and resolve other Section 482 issues for a variety of industries, including pharmaceuticals, semiconductors, high-tech equipment, satellite telecommunications, food and beverages, automotive vehicles and parts, retail, financial services, mining, and oilfield services.
- In business valuation projects, Mr. Gray has been involved with projects valuing closely held firms in the publishing, auto parts, food and beverage, semiconductor, and other high-tech industries, as well as issues valuing large blocks of public companies for estate tax purposes. He has also valued tangible and intangible corporate property for state property tax purposes. He has also developed procedures for determining royalty rates between licensor and licensee for tangible and intangible property and for calculating profit splits using the capitalized intangible investment method.
- Worked on economic consulting engagements, including civil and business litigation cases involving the calculation of economic damages and trade remedy cases before the International Trade Commission, the office of the United States Trade Representative and the World Trade Organization (WTO). These engagements have included anti-dumping, CVD, Section 201 and Section 337 proceedings, and WTO trade dispute resolutions in a variety of industries, including steel, bearings, aircraft manufacturing, crude oil, and synthetic rubber. Mr. Gray has also prepared expert testimony and appeared as an expert witness before the U.S. International Trade Commission.
- Director, global financial services firm
- Manager, economic consulting firm
- Senior Economist, economic consulting firm
PUBLIC SECTOR EXPERIENCE
- Financial Analyst, Securities and Exchange Commission
- Conducted research of interest to the Commission and the U.S. Congress, including studies of offshore capital raising activities, shareholder activism, and mutual fund expenses.
Mr. Gray has co-authored several papers on matters related to licensor-licensee relationships, the appropriate return to intangibles, and intangible property valuation. He has also prepared reports and/or given expert testimony related to economic valuation matters for clients in trade disputes before the International Trade Commission.
- A Probabilistic Approach to the Use of Econometric Models in Sunset Reviews, WTO Working Paper, February 2006 (with Alexander Keck and Bruce Malashevich)
- Does a Small Firm Effect Exist when Using the CAPM? Not Since 1980 and Not when Using Geometric Means of Historical Returns, Business Valuation Review, Vol. 18, No. 3, September 1999 (with Brian Becker)
- Capital Raising in the Offshore Market, The Journal of Banking and Finance, Vol. 23, Issue 8, August 1999 (with Reena Aggarwal and Hal Singer)
- Using Average Historical Data for Risk Premium Estimates: Arithmetic Mean, Geometric Mean, or Something Else? Business Valuation Review, Vol. 17, No. 4, December 1998 (with Brian Becker)
- The Licensor – Licensee Split: A Microeconomic Analysis (with Tim Reichert)
- How to Accurately Price and Design Intercompany Debt (with Tim Reichert, Nathan Callard, and Erin Hutchinson)
- Deposition testimony, Cypress Semiconductor vs. Altera Corporation, December 6, 2001
- Testimony, Certain Emulsion Styrene-Butadiene Rubber from Brazil, Korea, and Mexico (Investigations Nos. 731-TA-794-796), International Trade Commission, April 22, 1999
HONORS AND AWARDS
- NationsBank Scholarship, Georgia Institute of Technology
- Graduated with Highest Honors, Georgia Institute of Technology
- Graduated as top Senior in Economics Department, Georgia Institute of Technology
- Master of Arts Degree, Economics, Johns Hopkins University
- Bachelor of Science Degree, Economics, Georgia Institute of Technology