Jeff has more than 15 years of experience advising taxpayers on transfer pricing matters, intangible asset valuations and other complex corporate valuations. He works closely with some of the largest companies in the world and has advised or represented his clients during IRS tax audits, foreign tax audits, IRS fast-track negotiations, competent authority negotiations and Advanced Pricing Arrangement (“APA”) negotiations. Drawing on this tax controversy experience he also plays a critical role in designing, planning and executing his clients transfer pricing documentation strategies, particularly during periods of business reorganizations.
Mr. Cole has extensive experience in transfer pricing issues surrounding intangible assets and services and has spent much of his recent career advising clients on pricing intercompany intangible transfers as well as establishing R&D cost sharing arrangements.
After serving an appointment to the International Monetary Fund, where he authored papers on Canadian business taxation, U.S. income distribution, and Canadian public debt management, Mr. Cole started his transfer pricing career at KPMG, LLP and was one of a handful of equity partners that founded the Ballentine Barbera Group, LLC (“BBG”), which was later acquired by Charles River Associates (“CRA”). He left CRA to become a founding partner in the Washington, D.C. practice of Transfer Pricing Associates, LLC a Dutch advisory firm.