Akihiko Tsuda

Aki's practice focuses on negotiations with the NTA and IRS regarding bilateral and unilateral advance pricing agreements (APAs) and mutual agreement procedures (MAPs), design and implementation of TP policy, preparation of BEPS-related documentation and contemporaneous transfer pricing documentation, valuation, restructuring of global supply chains, tax audit support, preparation and execution of cost sharing agreements (CCAs) and transfer pricing planning.

• Engaged in a number of Japan-US bilateral APAs involving companies in a variety of industries, including automotive, transportation equipment, electronics, pharmaceuticals, precision and medical equipment, IT, sporting goods, office utilities and energy.
• Designed and supported the implementation of TP policies for multiple major manufacturing companies, including negotiations with foreign related entities.
• Prepared various reports for compliance purposes in a variety of industries, including Master Files (MFs), Local Files (LFs) and US Concurrent Documentation (6662).
• Engaged in many IP valuations.
• Provided many supply chain-related services, including transfer pricing optimization through transfer pricing supply chain restructuring in Japan, the US and Mexico as well as supply chain analysis and recommendations regarding non-renewal of Advance Pricing Agreements (APAs).
• Handled transfer pricing tax audits in Japan and the US.
• Provided assistance to major manufacturing companies entering into and renewing multiple cost contribution arrangements (CCAs).