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Ednaldo Silva, who has a PhD in economics from University of California, Berkeley, is a leading international expert in transfer pricing and the valuation of intangibles.
Dr Silva began his career as the first senior economic adviser in the Internal Revenue Service (IRS) Office of Chief Counsel before serving as the first economist in the IRS Advanced Pricing Agreement programme. During this time, he was a drafting member of the 1994 US transfer pricing regulations and introduced the ‘comparable profits method’ and ‘best method’ rule.
In his private practice and as managing director of RoyaltyStat, he has served as senior tax economist to large multinational corporations and economic consultant in high-profile IP and tax litigation, including the $3.4 billion settlement in GlaxoSmithKline Holdings (Americas) Inc v Commissioner of Internal Revenue.
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