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Summary

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.

Education

PhD, International Business, University of South Carolina

MBA, International Trade, Texas A&M International University

BA, Spanish/French, Southern Methodist University

Languages

Selected Work

Selected Experience

  • Estimated losses related to seller misrepresentations during negotiations. Adapted forecasts to estimate damages to the buyer.
  • Developed first price analyses to support customs positions.
  • 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.
  • 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.
  • Developed global documentation master files to demonstrate compliance with arm’s-length standard in multiple jurisdictions worldwide.
  • Developed rebuttal for IRS position related to royalty payments received by a US multinational.
  • 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.
  • Established arm’s-length returns for internet banking operations for two multinational banks. Integrated profitability and service charges to match the structure of operations.
  • Established economic analysis for bilateral Japanese-US APA negotiation to close 12 open years with no adjustment. The IRS withdrew all proposed adjustments. 
  • 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.

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