Stephen is a director in KPMG’s Global Transfer Pricing Services practice based in Atlanta. He works with multinational clients to structure, price, and document intercompany transactions in accordance with U.S. transfer pricing rules, the OECD Guidelines, state tax laws, and to meet regulatory requirements.
With more than 20 years of transfer pricing experience, Stephen is responsible for providing economic analyses to help taxpayers determine “arm’s length” support for the license of intangible assets, sale of tangible products, provision of services, and loans to support transfer pricing planning and compliance requirements. He has served as a testifying and consulting expert witness on transfer pricing in high profile state tax court and federal cases. Examples include:
- Lead engagement and relationship director on a large value chain transformation project resulting in a U.S. publicly-traded company converting to a dual principle structure. This planning project involved determining arm’s length pricing for the sale of intangible asset rights, cost-sharing of R&D, global procurement, and several new service and tangible product flows.
- Approved and testified as an expert witness in transfer pricing for a dispute involving the license of intangible assets at trial in New York state tax court.
- Trained in OECD BEPS Action 13 global transfer pricing requirements and skilled at preparing Master File, Local File, and Country-by-country reporting deliverables.
- Performed due diligence procedures on potential mergers and acquisitions to assess any existing international tax exposures that might impact the deal terms.
- Experienced at designing and implementing state transfer pricing structures to optimize cash flows and mitigate tax audit exposures.
- Routinely analyze, calculate, and document ASC 740 Uncertain Tax Positions for state, federal, and international intercompany transactions.
- Assisted companies with calculating and planning strategies related to BEAT, GILTI, and FDII provisions contained in the U.S. tax reform act.
- Subject matter expert in advising retail and e-commerce companies on establishing gift card programs to manage abandoned and unclaimed property.
- Engaged as an expert witness in Professional Malpractice for a U.S. District Court matter that involved defending the CFO of a publicly-traded company accused of aggressive transfer pricing practices.
Educational Background and Certifications
Stephen completed his MBA at Vanderbilt University, with concentrations in finance and accounting, and earned his BBA in finance from Texas Christian University. Stephen is a licensed CPA in the State of Georgia, a CVA, and a CGMA.
Publications and Speaking Engagements
Stephen has been published in several technical books and tax journals on a variety of transfer pricing topics. In addition, Stephen is a frequent speaker for ATLAS, CITE, TEI, and the International Bar Association.