Mark P. Thomas, PC, advises clients on all aspects of taxation, including complex civil tax controversies and litigation, transfer pricing, and domestic and international tax planning issues.
Mark has extensive transfer pricing planning, compliance, and dispute resolution experience in a broad array of industries that include manufacturing, pharma, entertainment and technology, retail and distribution, food and beverage, and financial services. He also has significant experience in structuring advance pricing agreements on a global basis. A substantial portion of Mark’s practice is devoted to handling the myriad valuation issues associated with mergers, acquisitions, divestitures and other transfers that often have significant tax and transfer pricing implications.
On the controversy side, Mark has extensive experience in resolving a broad spectrum of domestic and international tax matters at all stages of a dispute, including US Internal Revenue Service (IRS) examinations, administrative appeals and litigation. Where appropriate, he has utilized collaborative dispute resolution tools such as advance pricing and pre-filing agreements, and the Compliance Assurance Program Process. He has significant experience engaging with foreign tax authorities as well as a deep understanding of Organization for Economic Co-operation and Development (OECD) principles. The vast majority of Mark’s cases are resolved administratively and without becoming public.