About the Contributor

Dr. McClure has over 17 years of transfer pricing and valuation experience and currently holds the title of Senior Manager for ONESOURCE Transfer Pricing. He began his transfer pricing career at the Internal Revenue Service in San Jose, California and has worked for some of the Big Four accounting firms as well as a litigation support entity. Dr. McClure has assisted multinational firms with both U.S. and foreign documentation requirements, IRS audit defense work, and preparing the economic analyzes for bilateral and unilateral Advanced Pricing Agreements. Dr. McClure has also assisted clients with both international and multi-state tax and transfer pricing planning work. These planning projects have included the valuation of transferred intangible assets, the determination of arm’s length royalty rates, intercompany loan rates, intercompany lease rates, and the analysis of a related party distributor’s gross margin under a market share strategy. Dr. McClure has also worked on several projects that evaluated the interplay between transfer pricing and the valuation of a subsidiary. In his role as a Senior Manager at KPMG, Dr. McClure was responsible for the quality review of numerous reports from around KPMG’s U.S. practice. Dr. McClure was also responsible for the transfer pricing aspects of the FIN 48 review for many of KPMG’s audit clients. Finally, Dr. McClure worked with KPMG’s merger and acquisition team on the tax due diligence for its clients. Dr. McClure taught economics at the graduate and undergraduate level before his transfer pricing and valuation career. He had published several academic and transfer pricing papers including the OneSource White Paper on Intercompany Loans as well as “Alternative Approaches to Determining an Arm’s Length Royalty”, IDEA: The Journal of Law and Technology, Volume 43, 2002.

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