Gene Tien

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


Gene Tien works with US and foreign multinationals on transfer pricing (TP) and other economic valuation issues, with a primary focus on the planning and dispute resolution of intangible property (IP) transactions and other value-added TP flows. Dr. Tien also works on economic development issues on a pro bono basis — including international fiscal devolution, water rights, and domestic social justice research. He regularly presents and writes about developments in international TP policy.

Practice Focus

Dr. Tien focuses on providing practical, commercial advice to multinationals on their transfer pricing needs. This includes the design and implementation of global pricing strategies as they relate to IP or value-creating activities, risk assessment from a holistic TP and tax perspective, and audit defense and dispute resolution. He serves clients in diverse industries with a high degree of TP audit exposure, including scientific instrumentation, medical devices, pharmaceuticals, digital offerings, retail, oilfield services and natural resources, branded consumer product goods, and the entertainment sector. In addition to his consulting practice, Dr. Tien writes on tax policy changes, such as developments in new international transfer pricing regulatory regimes and trends in US transfer pricing audits.

Representative Legal Matters

  • Assisted digital economy companies on evaluating IP onshoring alternatives, including modeling pre- and post- TCJA impacts.

  • Provided bilateral APA and foreign audit assistance for US multinationals on issues involving mobile tangible and intangible assets.

  • Advised major US retail and consumer goods companies regarding Asia IP valuations, joint transfer pricing and customs exposures, and related issues pertaining to dutiability for customs purposes.

  • Counseled major technology companies with respect to their global transfer pricing policies post-restructuring, including accounting implementation, customs, documentation, and business combinations.

  • Collaborated on foreign transfer pricing controversy strategies ranging from audit defense to litigation positions for companies in various health-based industries, and others involving complex business models.

  • Defended various high-technology companies in their R&E tax credit positions by applying statistical techniques and interfacing with IRS field economists and engineers.

  • Assessed tax exposure risk for multiple US-based multinationals in connection with acquisition activity or in response to increased foreign audit scrutiny.

  • Counseled a major consumer software company with regard to its international restructuring relating to the US, Canada, and Singapore.

Professional Associations and Memberships

  • American Economics Association


  • Northwestern University (2004)
  • Northwestern University (1995)
  • University of Washington (1994)


  • English

Presenter on topics relating to IP onshoring post-TCJA, trends in TP controversy post-BEPS, and supply chain and regional HQ planning in light of OECD promulgations

Author of articles on OECD Actions 8-10 developments, the socio-economic impact of tax policy changes in Asia, and trends in US transfer pricing audits