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 his transfer pricing experience in numerous litigation matters, supporting experts in the preparation of expert reports and testimony for all types of intercompany transactions, including those involving complex intellectual property. He has significant experience in analyzing the pricing of intercompany transactions for global tax authorities, including those in the US, Australia, Canada, France, Germany, Italy, and the UK. 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. 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 from 2015 to 2022. He has also advised clients on transfer pricing and tax controversy in his work at public accounting firms and economics consulting firms.
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March 28, 2023