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Farnaz Amini
Ph.D., Transfer Pricing Lead
Dr. Farnaz Amini, the transfer pricing lead of the International Tax group, specializes in evaluating and developing related party transactions, as well as helping her clients optimize their transactions and meet regulatory and compliance requirements. She has over a decade of experience in practicing economics and transfer pricing, with clients from Fortune 50 multi-national corporations to private equity and hedge funds. She has extensive experience assisting clients in the financial services, technology, real estate, industrial and apparel industries with their transfer pricing compliance and consulting needs.
Expertise
Her expertise includes:
- Planning and evaluating complex intercompany arrangements from US Section 482 and OECD Guidelines perspectives
- Performing economic analyses including technical comparables benchmarking, pricing models, intangible asset valuations, APAs, cost allocations, and financial and economic modeling
- Evaluating related party financial transactions involving REITs, intercompany loans and fee splits
- Preparing Section 482 and OECD Guidelines compliant transfer pricing planning and documentation studies
- M&A transfer pricing due diligence analysis
Insights & Events
- November 17, 2021 The Tax Court Ruling Raising Coca-Cola’s Tax Bill to More Than $3 Billion and its Implications for Your Related Party Transactions
In a not so common outcome, on November 18, 2020 the US Tax Court upheld two Internal Revenue Service (“IRS”)...
Read more - November 17, 2020 Blockchain Technology Firms’ Transfer-Pricing Issues
Friedman's Farnaz Amini, Ph.D., and Adnan Islam, Esq., CPA, LL.M. were featured in a comprehensive article covering blockchain and transfer pricing....
Read more - May 1, 2020 When Asset Values Fall, Tax Opportunities Arise
[This article was updated on April 29 to reflect the IRS’ §7520 for May 2020] While it is worrisome to watch...
Read more
- November 17, 2021 The Tax Court Ruling Raising Coca-Cola’s Tax Bill to More Than $3 Billion and its Implications for Your Related Party Transactions
In a not so common outcome, on November 18, 2020 the US Tax Court upheld two Internal Revenue Service (“IRS”)...
Read more - November 17, 2020 Blockchain Technology Firms’ Transfer-Pricing Issues
Friedman's Farnaz Amini, Ph.D., and Adnan Islam, Esq., CPA, LL.M. were featured in a comprehensive article covering blockchain and transfer pricing....
Read more - May 1, 2020 When Asset Values Fall, Tax Opportunities Arise
[This article was updated on April 29 to reflect the IRS’ §7520 for May 2020] While it is worrisome to watch...
Read more