Brian Arthur is a partner in Baker McKenzie's New York office, where he advises on international and US federal taxation. Mr. Arthur regularly presents on transfer pricing and international tax issues for organizations such as Bloomberg BNA and various Firm client seminars. He has also authored several articles on these topics.
Mr. Arthur focuses on federal transfer pricing, international tax controversy and international tax planning. He also counsels on audits, appeals, litigation, competent authority and other stages of dispute resolution.
Representative Legal Matters
Advising a large, multinational banking group on the transfer pricing implications under the global dealing regulations of their trading activity in the US, London, and Hong Kong.
Representing a business process outsourcing company in competent authority proceedings for proposed transfer pricing and permanent establishment adjustments by the Indian tax authorities.
Representing oil and gas partnerships in proceedings involving the IRS' disallowance of intangible drilling costs.
Representing a pro bono client in an Internal Revenue Service collection action and successfully reducing a tax liability of over USD600,000 to under USD30,000 when the Internal Revenue Service had already filed liens on the client's assets.
Professional Associations and Memberships
- J. Edgar Murdock American Inn of Court
- California~United States (2010)
- New York~United States (2009)
- U.S. Court of Appeals, Fourth Circuit~United States (2006)
- District of Columbia~United States (2006)
- U.S. Tax Court~United States (2006)
- Florida~United States (2003)
- Nevada~United States (2003)
- University of Florida (LL.M. Taxation) (2004)
- University of Florida (J.D. Honors) (2002)
- University of Florida (Masters of Accounting) (2002)
- University of Florida (B.S. Honors) (1998)
- Co-presenter, “Thinking Strategically about Country-by-Country Reporting,” Baker McKenzie Global Tax Disputes Forum, New York, NY, December 2017
- Co-presenter, “Planning while Managing Transfer Pricing Disputes,” Baker McKenzie Transfer Pricing Workshop, July 2017
- Co-presenter, “Sales and Marketing Activities,” Baker McKenzie Transfer Pricing Workshop, July 2016
- Co-presenter, "U.S. Transfer Pricing Strategies for Inbound Investors," Bloomberg BNA, New York, NY, October 2015
- Co-presenter, "Analyzing Intercompany Services," Bloomberg BNA, Washington, D.C., June 2015
- Co-presenter, "IP Licensing and Sec. 482 Transfer Pricing Issues," Bloomberg BNA, New York, NY, December 2014 and June 2013
- Co-author (with M. Levey and P. Gordon), "US Taxation of Foreign Controlled Businesses," Chapter 1 Warren, Gorham and Lamont
- Co-author (with M. Levey, P. Carmichael and I. Gerdes), "Transfer Pricing: A Case Study (Methods and Documentation)," BNA Tax Management Portfolios 6912 T.M., 2016