Philip Carmichael is a principal economist in Baker McKenzie's New York office. He has advised several US-based companies on global transfer pricing including transfer pricing analysis, planning, documentation and dispute resolution. He has also coordinated and prepared documentation to serve the needs of tax authorities across different jurisdictions. In transfer pricing disputes, he has assisted in the preparation of economic analyses and responses to information requests, as well as advised on strategy. Prior to joining Baker McKenzie, Mr. Carmichael was a principal in the economic and valuation services practice of KPMG LLP.
Mr. Carmichael focuses on global transfer pricing, valuation, economic analysis and intellectual property transactions in the context of global business restructurings. He advises clients on a wide range of matters including restructuring intercompany arrangements for tax planning, preparing US and foreign documentation, valuing intangible assets and audit defense. He has led numerous important engagements for clients in which licensing, cost-sharing and/or intellectual property migration have been a central strategy. His work spans a number of industries, including business products, industrial products, luxury goods, software and technology.
Representative Legal Matters
- Advised on a number of large tax planning/restructuring engagements for major clients, covering multiple product lines and multiple tax jurisdictions.
- Advised clients on converting entities to contract and toll manufacturers, converting sales offices to commission agents and commissionaires, creating new HQ operations, restructuring service entities, migrating intangible property, and establishing cost sharing arrangements.
Professional Associations and Memberships
- National Association of Business Economics - Member
- Georgetown University (M.B.A.) (1989)
- University of Notre Dame (B.A.) (1984)
Speaker, “Limitations on State Transfer Pricing Adjustments,” State Tax Notes, 13 December 2010
Speaker, “Marketing Intangibles Undergoing Close Legal, Tax Scrutiny,” Tax Management – Transfer Pricing Special Report, 5 June 2008
Co-author, “Sarbanes-Oxley and Its Implications for Transfer Pricing,” International Tax Review, July 2005
Baker & McKenzie Consulting LLC provides tax advisory and economic services and does not provide legal advice or services. Baker & McKenzie Consulting LLC is a subsidiary of Baker & McKenzie LLP, a member firm of Baker & McKenzie International, a Swiss Verein of member law firms around the world.