Donna McComber

Donna McComber

Principal Economist
Baker & McKenzie Consulting LLC
Not admitted to practice law in this jurisdiction

Biography

Donna McComber is a principal economist, based in the Firm’s Washington, DC office. With more than 25 years of international tax experience in the US Government and private practice, Donna is widely recognized as an expert in transfer pricing matters, including negotiating advance pricing agreements (APAs) and mutual agreement procedures (MAPs) with the US Government and US treaty partners.

Prior to rejoining Baker McKenzie, Donna was a Principal in the national tax group of a Big Four accounting firm, providing transfer pricing guidance to multinational clients across a diverse range of business sectors. Earlier in her career, Donna served as a Senior Economist and Principal Economist for Financial Products within the Internal Revenue Service’s Advance Pricing and Mutual Agreement (APMA) Program, ultimately advancing to Deputy Director (Technical) and later an Assistant Director. While at APMA, she led teams responsible for managing and negotiating complex transfer pricing cases with foreign tax authorities with over 20 countries around the world. She was tasked with confirming a global view of strategic challenges and policy development, managing issues arising within APA and MAP case inventory, and focusing on strategic challenge areas such as BEPS, annual reports, and training. While at APMA, Donna was also a key contributor to the final adopted version of the cost sharing regulations.

Practice Focus

Donna advises multinational clients on complex cross-border transactions, including unilateral, bilateral, and multilateral APAs and MAP requests. She also leads engagements to analyze intercompany transactions and develop creative and practical transfer pricing solutions, advising clients on intellectual property planning projects, and global restructuring and audit readiness. Donna’s clients include leading multinational corporations across nearly all industries.

Professional Honors

  • Stuart L. Brown National Technical Guidance Award, Internal Revenue Service

Professional Associations and Memberships

  • NABE Transfer Pricing Symposium Planning Committee
  • Internal Revenue Service - Enrolled Agent (unrestricted, admitted to practice before the IRS for all matters)

Education

  • Vanderbilt University (MA, Economics)
  • Mary Washington College (BA, Economics)

Languages

  • English

Contributor, “Managing Transfer Pricing Audit Risks,” CPA Journal, 2002

Co-author, “INSIGHT: Advance Pricing Arrangements—The Quest for Certainty in Times of Uncertainty,” Bloomberg Tax, 2020

Co-author, “Covid-19: Impact on (the Other) TP,” BNA, 2020

Co-author, “Digital Revolution: Transfer Pricing on the Global Tax Battlefield,” BNA, 2021

Co-author, ”Exchange of Information in the New Era of Multilateral Transfer Pricing Enforcement,” Tax Notes International, April 29, 2024, p. 661