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, financial instrument valuation, 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.
PhD, International Business, University of South Carolina
MBA, International Trade, Texas A&M International University
BA, Spanish/French, Southern Methodist University
- Supported testifying expert in pharmaceutical case regarding economic substance, valuation of intangibles transferred, and the commensurate with income standard.
- Supported testifying expert in transfer pricing case regarding the valuation of intangibles transferred, and the commensurate with income standard.
- Provided economic analysis to support client's bilateral APA, including highlighting issues with APMA position.
- Established valuation of trade name transferred among related parties and successfully responded to HMRC questions and counter arguments.
- Estimated losses related to seller misrepresentations during negotiations. Adapted forecasts to estimate damages to the buyer.
- Established economic analysis for bilateral Japanese–US APA negotiation to close 12 open years with no adjustment. The IRS withdrew all proposed adjustments.
- Developed global documentation master files to demonstrate compliance with arm’s-length standard in multiple jurisdictions worldwide.
- 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.
- 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.
- 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.
- Structured loans for different call, put, and other optionality features to comply with the arm’s-length standard.
- Valued a loan portfolio for a subprime auto lender. Forecasted cash flows using historical collections and estimated required return of portfolio based on forecast accuracy.
- Valued employee stock options according to FASB 123 for financial statement purposes.
- Valued electricity forwards for financial statement purposes.