PRIVATE SECTOR EXPERIENCE
- Principal, Economics Partners – a Ryan Company, Washington, D.C. office
- More than 15 years of experience in transfer pricing matters, intangible asset valuations, and other complex corporate valuations.
- Designs, plans, and executes transfer pricing documentation strategies, particularly during periods of business reorganizations.
- Advises on pricing intercompany intangible transfers, as well as establishes research and development (R&D) cost-sharing arrangements.
- Partner, transfer pricing and business valuation firm
- Advised or represented clients during Internal Revenue Service (IRS) tax audits, foreign tax audits, IRS fast-track negotiations, competent authority negotiations, and advanced pricing arrangement (APA) negotiations.
- Founding Partner, transfer pricing and advisory firm
- Vice President, global consulting firm
- Partner, transfer pricing consulting accounting firm
- Senior Manager, Transfer Pricing, Big Four accounting firm
- Senior Consultant, Transfer Pricing, Big Four accounting firm
PUBLIC SECTOR EXPERIENCE
- Research Analyst, International Monetary Fund
Mr. Cole has authored various papers on:
- Canadian business taxation
- Canadian public debt management
- U.S. income distribution
- Valuing Intangibles under Cost Sharing Arrangements, Tax Director’s Guide to International Transfer Pricing, Edited by Kenneth R.L. Parker, April 10, 2008
- A Residual DCF Approach to Valuing Forgone Profits, BNA Tax Management Transfer Pricing Report, May 25, 2005
- How you can combine risk and the arm’s length standard, International Tax Review’s Regional Guides, No. 5, North America, 2005
- Adjusting for Differences in Risk Levels Between Tested Parties and Comparable Firms, BNA Tax Management Transfer Pricing Report, May 14, 2003
- Medicare: Financial Problems and Reform Options, United States-Selected Issues, International Monetary Fund (SM/97/97), July 1997
- Business Taxation in Canada, Canada-Selected Issues, International Monetary Fund (SM/97/20), January 1997
- Income Distribution and Macroeconomic Performance in the United States, International Monetary Fund Working Paper Series (WP/96/97), August 1996
- Federal and Provincial Debt and Debt Management Strategies, Canada-Selected Issues, International Monetary Fund (SM/96/96), March 1996
- Master of Science Degree, Economics (Emphasis in Finance), University of Delaware
- Bachelor of Science Degree, Math and Economics, Ithaca College