Salim Rahim has extensive experience in transfer pricing matters, including transfer pricing planning, compliance, and tax controversy. He is a member of the management committee of the Firm’s North America Transfer Pricing Subpractice Group. He also serves on the editorial committee for Tax News and Developments, the North America Tax Practice Group’s bi-monthly newsletter. Mr. Rahim is a frequent speaker on transfer pricing matters in seminars sponsored by various organizations and universities.
Mr. Rahim advises clients on matters involving transfer pricing planning, restructuring, examination, appeals and competent authority. He has represented clients in all administrative phases of a controversy through litigation in the US Tax Court. He has also represented companies in various alternative dispute resolution forums, particularly the Advance Pricing Agreement Program. In particular, his practice involves negotiating and consummating advance pricing agreements for US and foreign-based multinational companies in the software, e-commerce, pharmaceutical, manufacturing, automobiles, sports footwear and apparel, financial services and other industries. Mr. Rahim also advises companies on global transfer pricing documentation requirements.
Representative Legal Matters
- Advised First Data Corporation and Subsidiaries on various transfer pricing issues and other international tax issues under sections 482 and 367(d).
- Negotiated multiple advance pricing agreements for software companies with intercompany transactions between affiliates based in the US and Korea.
- Advised a medical device company on the transfer pricing and related tax consequences of a cross-border restructuring of the company’s intangible property holdings and manufacturing operations.
- Negotiated one of the first bilateral advance pricing agreements involving the US and China for a software company.
- Negotiated a unilateral advance pricing agreement involving a buy-in transaction for an internet search and advertising company.
Professional Associations and Memberships
District of Columbia~United States (2004)
Maryland~United States (2003)
George Washington University
George Washington University School of Business and Public Management
(Master of Science Finance)
Edinboro Univ. of Pennsylvania
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