By Natalie Posgate
Staff Writer for The Texas Lawbook
McDermott Will & Emery is getting a leg up in the world of transfer pricing. The Chicago-based firm is acquiring a seven-person, internationally recognized transfer pricing team in the firm’s Texas offices, led by prominent tax lawyers Cym H. Lowell and Mark R. Martin.
Both Lowell and Martin come to McDermott from Gardere Wynne Sewell. They have co-authored several important treatises on U.S. international transfer pricing, U.S. international practice and procedure and U.S. international taxation. Lowell and Martin’s team is at the forefront of the evolution in transfer pricing.
The group has significant experience with negotiating advance pricing agreements and handling competent authority cases between the U.S. and its treaty partners. It also has in-depth experience with international practice matters, which include handling inbound and outbound transfer pricing and controversy matters in Japan.
Lowell will practice out of a satellite office in Dallas with three professional advisors: managing director Hiroaki Furuya, economist Tracy Gomes and financial analyst Haiyan Zhang.
Lowell’s experience involves working on a multitude of planning and controversy matters for U.S. and foreign-based international companies as well as wealthy individuals. His transfer pricing cases have involved proposed adjustments in the billions and he has structured advance pricing agreements on a global basis. Lowell is currently the vice-chairman of the International Chamber of Commerce Taxation Commission and is a member of the Business and Industry Advisory Committee to the Organization for Economic Cooperation and Development (OECD) and U.S. Council of Business.
Martin will become the new head of McDermott’s transfer pricing practice and will work in the firm’s Houston office. Joining him will be partner John T. Woodruff and associate Mark Horowitz.
Martin’s background involves expertise in multinational energy, construction and chemical clients, and he is well known for resolving transfer pricing matters through unilateral and bilateral processes. He specializes in resolving critical transfer pricing issues through emerging dispute resolution processes in the U.S. and other countries. He is the incoming chair of the Transfer Pricing Committee of the American Bar Association and is the former chairman of the International Tax Committee of the State Bar of Texas.
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