Robert Feinschreiber and Margaret Kent

Executive Summary - Accomplishments - Present and Past Activities

Education Completed 5 years of post-graduate education at Yale University School of Law and at Columbia Graduate School of Business, all by age 24
Teaching Became the youngest full-time law professor in the United States when appointed (Wayne State University), age 23
East-West Trade First American to teach in Moscow State University after the Cold War
Litigation Member of the litigation team for the first Asian transfer pricing case (Toyota)
Publications Prepared more international tax articles than did other tax professionals
Written or co-authored 20 tax books, more than by any other tax professional
Editorial Advisory Boards currently Wolters Kluwer – CCH, and Thomson - RIA
Transfer Pricing Edited the Transfer Pricing Handbook – all three editions, authored the guidebook for foreign-owned corporations for John Wiley & Sons, Inc.
Conferences Lectured and chaired many tax conferences in the United States and later in Asia
Legislative drafting prepared statutes and regulations
U.S. Tax Court quoted as being an “authority”
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Cited by Business Week, by Forbes, and by The Wall Street Journal
UN consultant Assigned to Brazil, China, and Russia
Other expertise CPA
Directorships International Tax Institute, private business corporations|
Client representations Represents businesses in tax planning, tax audits, and pre-litigation
Successful defense against tax administrations:

  • Successfully defended international taxpayers against IRS economist examiner transfer pricing attacks
  • Developed in-house comparables transfer pricing strategies for our clients, avoiding data bases and data provider fees
  • Substantiated reinvoicing structures in a tax haven.
  • Successfully defended foreign-based multinational taxpayer as to SIC/NAICS categorization under transactional net margin method
  • Successfully defended multinational corporations against IRS documentation claims
  • Successfully defended multinational corporations against tax administration claims for services activities   
  • Privatization Participated in the structuring of privatization and direct foreign investment alternatives in transitional economies

Bar Membership New York and Florida

International law and taxation – focus on transfer pricing

Expert witness assignments (selected)
For a plaintiff in complex securities law litigation
Tax malpractice litigation against a big four accounting firm involving international tax                   structuring
Transfer pricing litigation involving valuation issues               

Education
Stuyvesant High School, 1960
B.A. Trinity College, Hartford, Connecticut 1964
LL.B Yale University School of Law, New Haven, Connecticut 1967
M.B.A. Columbia University Graduate School of Business, New York City, 1967
LL.M in Taxation, New York University, New York City, 1973

Tax Books Authored or Edited (selected books)
Fundamentals of International Taxation (first and second editions) (PLI) (co-author)
Domestic International Sales Corporations (PLI)
            FFSC: The Foreign Sales Corporations (Corporate Tax Press)
Tax Incentives for U.S. Exports (Oceana)
Tax Depreciation under the Class Life ADR System ( Amacom Am. Mgt. Assoc.)
International Tax Planning Today (Panel)
Subpart F (Panel)
Earnings and Profits (Panel)
Allocation and Apportionment of Deductions (Panel)
International Reorganizations (Panel)
Export Handbook (Wiley)
Import Handbook (Wiley)
Avoiding Tax Malpractice (CCH)
International Reorganizations (Wiley)
Tax Reporting for Foreign Owned Corporations (Wiley)
Transfer Pricing Handbook (first, second, and third editions) (Wiley)
Transfer Pricing International (Wiley)
Transfer Pricing: An Applications Guide (Wiley)
Transfer Pricing 2008 (TransferPricingConsortium.com)
Transfer Pricing in Asia (TransferPricingConsortium.com)
OECD Transfer Pricing (underway, nearly completed)

Books Contributed
Kumar, Recent Treads and Prospects of Transfer Pricing
Choi, International Finance and Accounting Handbook
Mexico transfer pricing
PLI, International Reorganizations


Feinschreiber & Associates
Robert Feinschreiber & Margaret Kent

1121 Crandon Blvd. F301
Key Biscayne, FL 33149
Primary Phone: 305.361.5800
or 305.505.9200
Fax: 305.365.2276
multijur@aol.com
www.transferpricingconsortium.com
www.ExportDISC.com