- Alternative dispute resolution
- APA agreements
- Cost-benefit analysis
- Reasonable royalty analysis
- Equity, fixed-income, and derivatives securities valuation
- Intangibles valuation
- Intellectual property
- Transfer pricing analysis
- Transfer pricing audits
- Banking and financial services
- Financial services
- Internet-related services
- Media and entertainment
- Online content providers
Alan Alford has extensive experience analyzing complex transactions involving transfer pricing, integration of acquired companies, valuation, and cross-border issues. He has substantial audit, licensing, valuation, and financial analysis experience in the computer software, banking and financial services, healthcare, semiconductor, and oil and gas industries.
He specializes in the pricing and licensing of intangibles and intellectual property, financial services transactions, integration of acquisitions, corporate restructurings, entity valuations, establishing terms for related-party loans, negotiation of Advance Pricing Agreements (APA), and dispute resolution.
Prior to joining Bates White, Dr. Alford held senior tax positions at Thomson Reuters and KPMG, as well as academic positions at multiple universities worldwide.
- Conducted economic analysis of intercompany transactions to establish appropriate arm’s-length pricing for various intangibles, valued intellectual property from acquired businesses for consolidation, valued legal entities for corporate restructurings, and documented related-party transactions worldwide. Also, established transfer pricing policy on ancillary transactions.
- Developed global documentation master files to demonstrate compliance with arm’s-length standard in multiple jurisdictions worldwide. Adapted the documentation, as appropriate, to specific standards of the local jurisdictions.
- Developed rebuttal for IRS position related to royalty payments received by a US multinational. Highlighted the inconsistency of the IRS’ position with the client’s business operations and the differences between the IRS’ comparable set and the relevant tested parties.
- Negotiated a unilateral APA in Spain regarding technology royalty being paid to a related party.
- Formulated audit defense for a Mexican subsidiary of a major multinational related to local manufacturing and distribution operations. Worked with client to illustrate issues in the tax authority’s economic analysis and the reasonableness of the established transfer pricing policy.
- Formulated an audit defense for a Canadian subsidiary of a major bank in support of its deposit guarantee; worked with counsel and client to demonstrate errors in the government’s economic analysis.
- Implemented models to demonstrate the arm’s-length nature of intercompany loans. Provided analysis for short-term borrowings from offshore related parties to finance loans to third parties. Priced long-term intercompany loans based on the related-party borrowers’ credit ratings and market conditions.
- Established arm’s-length returns for internet banking operations for two multinational banks. Integrated profitability and service charges to match the structure of operations. For one client, justified why no charges were appropriate in initial years, and for another, structured argument that losses were appropriate during the start-up phase.
- Established economic analysis for bilateral Japanese-US APA negotiation to close twelve open years with no adjustment. The IRS withdrew all proposed adjustments.
- Valued a loan portfolio for a subprime auto lender. Forecasted cash flows by using historical collections and estimated required return of portfolio based on forecast accuracy.
PhD, International Business, University of South Carolina
MBA, International Trade, Texas A&M International University
BA, Spanish/French, Southern Methodist University