Nathaniel Carden focuses on both planning and controversies arising in connection with transfer pricing and related international tax issues. Building on several years of experience as a management consultant with McKinsey & Co. and serving as a law clerk for The Honorable Diane P. Wood of the United States Court of Appeals for the Seventh Circuit, Mr. Carden specifically concentrates on the tax aspects of ongoing business operations.
Mr. Carden’s transfer pricing and operational planning practice focuses on planning and pre-audit issues arising from cross-border intangible property, service and financing transactions. He also has provided advice and related documentation concerning cross-border transactions and applying U.S. and Organisation for Economic Co-operation and Development (OECD) transfer pricing rules. Select representations include:
- large multinational companies in the tax aspects of operational integration following significant mergers and acquisitions;
- several large multinational corporations in connection with supply chain reorganizations intended to increase value of business units prior to disposition;
- a global food and consumer brands company in a strategic review of worldwide transfer pricing positions and impact on foreign tax credits and repatriation;
- a global exchange in the expansion of its international operations into the United Kingdom and Brazil;
- various operating companies in providing counsel concerning transfer pricing, valuation, compliance and other operating issues relating to conversion into and operation as specialty real estate investment trusts (REITs);
Mr. Carden’s dispute resolution practice emphasizes the representation of corporate taxpayers in pre-audit, audit, administrative appeal and litigation proceedings. He focuses on resolving substantive tax disputes and addressing discovery and evidentiary privilege issues arising from financial audits, IRS examination and litigation. Select representations include:
- various multinational companies in disputes with the IRS over the tax consequences of cross-border licensing, cost sharing, Section 936 conversion and similar transactions;
- global software and medical technology companies in disputes with the IRS and other tax authorities concerning the fees charged for contract research services performed in India, Singapore, China and other locations;
- a global food company in disputes with various tax authorities concerning operations in the United States, Mexico and Canada;
- large multinational corporations before IRS Examination and Appeals in complex corporate audits involving multiple U.S. federal consolidated groups;
- taxpayers in IRS summons enforcement action seeking planning memoranda and other materials prepared by attorneys and other tax advisers;
Education:
- J.D., University of Chicago Law School, 1999 (with High Honors; Order of the Coif; Book Review and Business Editor, 1998-1999; Staff Member, 1997-1998, The University of Chicago Law Review)
- B.A., Georgetown University, 1996 (summa cum laude; Beta Gamma Sigma)
Admissions:
- Illinois
- U.S. Tax Court
- U.S. Court of Appeals for the Seventh Circuit
- U.S. District Court for the Northern District of Illinois
Cost
Rate : $$$