People / Roberto Ferreira
Roberto Ferreira is a partner in the tax and regulatory practices. He has structured cross-border transactions involving more than 30 jurisdictions, and has resolved transfer pricing matters with the IRS, HMRC, and the Brazilian Receita Federal. He previously served as attorney-advisor in the Treasury Department's Office of Tax Legislative Counsel.
Roberto joined the firm in 2004. He teaches international tax at NYU Law.
Resolved a multi-year transfer pricing examination by the IRS Large Business & International division for a multinational technology company.
No adjustments; advance pricing agreement signed covering the next five years.
Defended a registered swap dealer in a CFTC enforcement investigation concerning trade reporting and supervision.
Matter closed with a no-action letter; no civil penalty.
Structured the cross-border reorganization of an industrial group to achieve a full step-up in basis across nine jurisdictions.
Implemented with no current tax cost; expected annual savings of $40M.