Salim Rahim is the chair of the Firm's Global Transfer Pricing Group. He has extensive experience in transfer pricing matters, including transfer pricing planning, compliance, and tax controversy. He has represented clients in all administrative phases of a controversy. Salim has also represented companies in various alternative dispute resolution forums, particularly the Advance Pricing & Mutual Agreement Program.
Salim is a frequent speaker on transfer pricing matters in seminars sponsored by various organizations and universities. He also participates in programs sponsored by Bloomberg BNA, Alliance for Tax, Legal and Accounting Seminars (ATLAS), Tax Executives Institute (TEI), International Tax Review, Organization for International Investment and the American Bar Association.
Salim advises clients on matters involving examination, appeals, advance pricing agreements, and competent authority. In particular, his practice involves negotiating and facilitating 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. Salim also advises companies on global supply chain restructuring and IP planning projects.
Representative Legal Matters
- Represented a global technology service and solutions provider in various transfer pricing issues and other international tax issues under sections 482 and 367(d).
- 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.
- Negotiated a unilateral advance pricing agreement involving a buy-in transaction for an internet search and advertising company.
Professional Associations and Memberships
- American Bar Association
- U.S. Tax Court~United States (2009)
- District of Columbia~United States (2004)
- Maryland~United States (2003)
- George Washington University Law School (JD Honors) (2003)
- George Washington University School of Business and Public Management (MS Finance) (1995)
- Edinboro University of Pennsylvania (BA Accounting) (1994)
Author, "The IRS's Transfer Pricing Roadmap: A Step Towards Putting the Horse Before the Cart," BNA Tax Management, Transfer Pricing Report, March 2014
Author, "The New U.S. Services Rules: Stewardship in the Disjunctive," BNA Tax Management, Transfer Pricing Report, August 2009
Author, "Cost Sharing Arrangements are Less Attractive under New Regulations", Journal of International Taxation, April 2009
Author, "IRS Issues Long-Awaited Temporary Regulations on Cost-Sharing Arrangements," INTERTAX Volume 37, January 2009
Author, "Proposed Cost Sharing Regulations Introduce "New" Standards," Journal of International Taxation, December 2005