Robert H. Green joined Skadden’s Washington, D.C. office as of counsel in March 2009. Mr. Green heads the firm’s transfer pricing practice worldwide.
Mr. Green’s experience extends across a broad range of international and corporate tax issues. Prior to joining Skadden, he was a member at another law firm in Washington, D.C. Immediately prior to that, Mr. Green was the director-international for the Internal Revenue Service. In that capacity, he served as the U.S. competent authority with responsibility for managing negotiations and achieving resolution on tax controversies with treaty partners of the U.S. regarding specific cases involving transfer pricing, permanent establishment, withholding and treaty interpretation matters. Mr. Green also was involved in the development of U.S. transfer pricing guidelines for international examiners to audit cost-sharing transactions and the development of settlement guidelines to resolve a substantial number of large cases involving cost sharing. In addition, Mr. Green was jointly responsible with the APA director for initiating the first bilateral APA with China. He also completed the MOUs with Canada and Mexico to enhance the resolution of bilateral tax cases with those countries.
Mr. Green has provided counsel to numerous clients on transfer pricing and related cross-border tax matters, including Goldman Sachs, 3M Company, Ford Motor Company, Pfizer, Fidelity Investments and GlaxoSmithKline.
Mr. Green’s practice involves providing counsel to clients in managing and resolving tax disputes arising from global, regional and bilateral business transactions, including:
- managed the successful resolution of a substantial bilateral tax dispute culminating in a completed bilateral APA and agreed competent authority case between the United States and Canada;
- restructuring cross-border business operations to minimize tax controversies relating to transfer pricing, permanent establishment, income characterization, withholding and treaty interpretation issues;
- structuring the offshore migration of intangibles in a tax-effective manner, including cost-sharing arrangements;
- providing counsel to clients in pursuing APAs, competent authority agreements and other dispute resolution tools to reach agreement on U.S. and international tax controversies;
- assisting clients in managing global tax risks for financial reporting purposes;
- working with U.S. and international tax authorities to resolve cross-border tax disputes; and
- managing tax controversies with the IRS arising from cost-sharing arrangements and other transfers of intangibles to foreign locations.
Mr. Green’s professional background includes corporate tax experience with Procter and Gamble as director of international tax in the corporate headquarters and then as director of taxes, Europe in P&G’s operations in Germany, where he was involved in the design and implementation of a global restructuring project. Previously, he served as vice president of tax policy for the National Foreign Trade Council, which represents U.S. multinational companies on international tax matters. Mr. Green also worked as tax counsel to a member of the House Ways and Means Committee of the U.S. Congress.
Mr. Green is a frequent speaker on transfer pricing and related issues arising in global tax controversies. He has chaired panel discussions on these subjects at the IFA Congress (Kyoto) and at ABA Tax Section Meetings. Mr. Green was invited to present testimony to the OECD relating to their project concerning the tax treatment of intangibles. Mr. Green is co-founder of the International Taxation Summit held annually in Beijing, China. The summit has become an important forum for the discussion of international and corporate tax issues in China and the greater Asian marketplace.
Mr. Green has been selected for inclusion in The Best Lawyers in America, Transfer Pricing Advisers Expert Guide and The International Who’s Who of Corporate Tax Lawyers.