Eric Torrey

Eric's practice primarily focuses on the resolution of transfer pricing disputes and tax planning of intercompany transactions. In his dispute resolution work he advises clients defending their transfer pricing in US or foreign audits, IRS appeals, and litigation. In particular, Eric has significant experience negotiating and facilitating advance pricing agreements (APAs) and Mutual Agreement Procedures (MAPs) for US and foreign multinationals. His tax planning work involves helping multinationals structure intercompany transactions in connection with reengineered supply chains, post-acquisition integrations, and other business restructurings. He also advises on certain transfer pricing documentation, primarily for companies with significant intellectual property. Eric routinely works with companies in industries such as industrial manufacturing; technology; automotive; telecommunications; pharma, medical devices, healthcare and life sciences; transportation and logistics; media and entertainment, and; retail and branded products.

• Directed APA submissions and facilitated negotiations between the US and various treaty partners including Switzerland, China, India, Germany, Canada, and Mexico, primarily for the licensing or transfer of intellectual property.
• Led project involving the restructuring of the research, development, ownership, and licensing of critical manufacturing technology for US-based multinational.
• Led the economic analysis and valuation efforts central to a tax dispute of a major US media company's restructuring of its operations in EMEA. A USD 1.4 billion proposed income adjustment was successfully resolved at appeals for 2% of the proposed adjustment.
• Assisted a US multinational in examining and quantifying the tax risk associated with the potential global restructuring of the management, performance, strategy and funding of their core intellectual property.
• Advised a major US pharmaceutical, medical device, and consumer goods company in the overhaul of their US transfer pricing documentation.
  
   

• National Association for Business Economics (NABE)
• United States Council for International Business (USCIB)

• Mexico City