Gene Tien has worked extensively with US and foreign multinationals on transfer pricing and other economic valuation issues for more than 10 years. He primarily handles the transfer and valuation of technology, with an emphasis on US transfer pricing audit defense and planning. Mr. Tien also works on post-conflict international development pro bono issues mainly relating to Asia — including fiscal aspects of constitutions, fiscal devolution, water rights and developmental aid. He also has extensive research experience on cross-sectional and panel microeconomics, international trade and development topics in Asia.
Mr. Tien focuses on applied microeconomics, including the design and implementation of global pricing strategies, intangible valuation and audit defense. His clients include consumer goods and electronic multinational corporations, oilfield service companies, as well as biotech and software developers. In addition to his legal practice, Mr. Tien has written articles on the socio-economic impact of tax policy changes in Asia, as well as trends in US transfer pricing audits.
Representative Legal Matters
- Advised a major US consumer goods company regarding the value of its Japanese and Korean intangibles, and the share of dutiability for customs purposes.
- Counseled a multinational semiconductor company with respect to its global transfer pricing policy, including issues pertaining to accounting implementation, customs, documentation, and business combinations.
- Defended R&E tax credit positions of a Fortune 500 electronics manufacturer by applying statistical techniques and interfacing with IRS field economists and engineers.
- Assessed tax exposure risk for a Global 500 construction multinational in connection with its acquisition activity.
- Advised a major US oilfield service provider in relation to the defense of its global transfer pricing policy.
- Counseled a major consumer software company with regard to its international restructuring relating to the US, Canada, and Singapore.
- Northwestern University (2004)
- Northwestern University (1995)
- University of Washington (1994)
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