Matthew Kramer advises clients on a broad range of transfer pricing planning and controversy matters, including advance pricing agreements, mutual agreement procedures under bilateral income tax treaties, business restructurings and intangibles migration. Prior to joining the firm, Mr. Kramer served for 11 years as team leader and special counsel in the Internal Revenue Service’s APA Program, where he negotiated advance pricing agreements between multinational corporations, the IRS and foreign governments, including Japan, Canada and the U.K. While in the APA Program, Mr. Kramer completed cases on a broad range of industries and countries, with an emphasis on intangible transfers, cost sharing transactions, platform contribution transactions and high-technology companies. Mr. Kramer also was instrumental in revising APA revenue procedures and in advising the IRS on matters relating to intangibles transfers. Prior to working in the government, Mr. Kramer was an associate at the Bay Area office of an international law firm, where he focused on international tax. Mr. Kramer has delivered presentations on topics including the taxation of intellectual property, the taxation of software and the creation of intangible property. Mr. Kramer is an assistant adjunct professor in the LL.M. Program in Taxation at Golden Gate University in San Francisco, where he teaches classes on transfer pricing. Mr. Kramer also has extensive experience as a lecturer and instructor of graduate and undergraduate courses in the humanities.
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