Transfer Pricing Controversy – The Tax Director’s View

Sonja is Senior Manager, Global Tax Controversy at Netflix, where she leads the global tax controversy function and strategy.  Prior to joining Netflix in January 2022, she was Principal Corporate Counsel at Microsoft, where she was the lead attorney managing international income tax controversies, including audits, administrative appeals, competent authority proceedings, and litigation and engagement on advance pricing agreements and tax rulings. Before Sonja joined Microsoft in 2018, she worked in the Chicago offices of Skadden, Arps, Slate, Meagher & Flom LLP and Baker & McKenzie LLP, where she advised individuals and multinational corporations at various stages of U.S. federal income tax controversies, including in U.S. Tax Court and federal court litigation.

Erin is Senior Director, Global Tax Disputes at Johnson & Johnson, where she leads a team responsible for global tax audits and dispute resolution.  Erin is responsible for setting and executing on strategies across all dispute resolution activities, from audits to competent authority requests, advance pricing agreements and tax rulings.  Erin also provides risk-management insights in planning and implementation, as well as advance pricing agreements and tax rulings.  Erin also provides risk-management insights in planning and implementation. Prior to joining Johnson & Johnson, in November 2021, Erin was a partner at Baker & McKenzie LLC, where she focused on all levels of tax controversy from audit through litigation in U.S. federal courts.  

Erin has had a strong focus on diversity, equity, and inclusion throughout her career. Erin is a member of the North America Tax DE&I Council at Johnson & Johnson. At Baker & McKenzie, Erin was Chair of the Diversity and Inclusion Committee for the New York and Miami offices and a member of the firm’s Anti-Racism Task Force. 

3M Career

Dec 2016 Senior Vice President, Tax and Real Estate

July 2015 Director, Tax Organization, Tax and Real Estate Department

Jan 2013 Director, Tax Planning, Tax and Real Estate Department

2008 Senior Tax Counsel, Tax and Real Estate Department

2006 Tax Counsel, Tax and Real Estate Department