Steve Allen
Education
M.B.A., strategic management, MIT Sloan School of Management; M.S., economics, and B.A., history, University of Kentucky
Summary of Experience
Mr. Allen specializes in transfer pricing and related global tax controversy matters, including the application of US and international transfer pricing regulations to all types of intercompany transactions. He has applied this experience in numerous litigation matters, supporting experts in the preparation of expert reports and testimony. He has significant experience in analyzing and defending the pricing of intercompany transactions to global tax authorities, including those in the US, Australia, Canada, France, Germany, Italy, and the UK, among others. Mr. Allen has expertise at all levels of tax authority engagement, including exam, appeals, litigation, and advance pricing agreements (APAs). His work has included analyzing transfer pricing for tangible goods, intangible property, services, and loans and other financing transactions. Across industries such as food and retail, IT and software, and pharmaceutical and biotech, his work has had a particular focus on intercompany franchising structures and related trademark and intangibles pricing. He also has considerable experience with cost sharing arrangements (CSAs), valuation of complex intellectual property for business and tax purposes, and tax accounting matters related to transfer pricing. Prior to joining Analysis Group, Mr. Allen was the director of Global Transfer Pricing for McDonald’s Corporation. He has also advised clients on transfer pricing and tax controversy in his work at public accounting firms and economics consulting firms.
-
March 28, 2023