Gene Tien Ph.D.

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


Gene Tien works with global multinationals on intercompany pricing and economic valuation issues that impact their most relevant tax positions. Gene assists in the design of intercompany transaction flows with an eye to reducing transfer pricing (TP) and other value-added pricing flow disputes. He specializes in valuing intangible property (IP) transactions, and the direct and indirect tax implications, assists companies in documenting and managing with the evolving TP and tax landscape, and regularly consults on dispute resolution and controversy matters globally. He regularly presents and writes about international TP policy, and on broader fiscal policy issues relating to economic development. For his Ph.D., he specialized in Industrial Organization with a dissertation on technology transfer and the structure of licensing contracts. His other areas of specialty included Economic History, International Economics, and Labor and Econometrics.

Practice Focus

Gene Tien provides practical, commercial advice to multinationals to address their intercompany 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 global audit defense and dispute resolution at a parent company and subsidiary level. He serves globally headquartered clients in diverse industries with a high degree of TP audit exposure, including digital offerings, scientific instrumentation, pharmaceuticals, medical devices, retail, oilfield / natural resource services and management, branded consumer product goods, and the entertainment sector.

Representative Legal Matters

  • Led non-US HQ'd global pharmaceutical company through bilateral APA and foreign audit procedures on topics such as cost sharing, IP transfers, and headquarter restructuring.
  • Defended numerous US multinationals on their overall TP strategy by managing local and US audit positions with tax controversy counsel in instrumentation, medical devices, pharmaceutical, oilfield services, and other industries.
  • Set global TP policies pre- and post-restructuring, including accounting implementation, customs, documentation, and business combinations, for major technology companies.
  • Provided non-US audit assistance to companies with local IP nexus issues to quantify royalty withholding exposures, and coordinate with global IP, tax, and litigation counsel.
  • Assisted numerous technology companies on evolving tax modeling issues, including restructuring for IP integration, Pillar Two, local country, and TCJA purposes.
  • 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.
  • Collaborated with tax counsel on IRS disputes on settlement and R&E tax credit modeling by applying statistical techniques and interfacing with IRS field economists and engineers.
  • Assessed tax exposure risk for US-based multinationals in connection with acquisitions and in response to increased foreign audit scrutiny.

Professional Honors

  • A highly regarded transfer pricing practitioner by most recent World Tax guide.
  • A member of Chambers USA 2023's Band One ranked practices in Tax in Northern California. 
  • A member of the Legal 500 2023's Tier One ranked practices in International Tax and US Tax: Contentious; and Tier Four in US Tax: Non-Contentious.

Professional Associations and Memberships

  • American Economics Association


  • Northwestern University (Ph.D. in Economics) (2004)
  • Northwestern University (M.A. in Economics) (1995)
  • University of Washington (B.A. with honors in Economics) (1994)
  • London School of Economics


  • English


Gene Tien writes on tax policy changes, such as developments in new international pricing regimes and trends in global TP audits. A list of recent publications follows:


Gene Tien speaks frequently on a variety of international pricing topics, such as transfer pricing and global tax policy, and lectures in conjunction with seminars sponsored by various organizations such as the Tax Executives Institute, the International Association for Drilling Contractors, and various law schools and business schools around the world.