Sahar Zomorodi

Ms. Zomorodi advises clients on US federal income taxation with a focus on international tax planning, transfer pricing, and tax controversy.

Visiting attorney from the New York office.
Provide U.S. tax, including international tax and transfer pricing advice.

Associate with the Tax Practice Group in the New York office.

• Focus practice on U.S. and international taxation, including transfer pricing, international tax planning and transactions for multinational corporations.
• Tasks include manage multi-year projects for international mergers, acquisitions, dispositions, and global restructurings of multinational corporations across disciplines and global offices; draft various legal documents such as US tax opinions, private letter ruling requests, intercompany agreements, and US treaty analyses.
• Manage client relationships beginning with the proposal stage and budget planning, through execution.
• Frequent speaker at Bloomberg BNA conferences and Baker & McKenzie conferences on transfer pricing.
• Frequent co-author of Baker & McKenzie articles and publications, such as Global Transfer Pricing Handbook and Global Legal Guide for Luxury & Fashion Companies.
• Active member of the Pro Bono and Diversity Committees.

Advanced Pricing & Mutual Agreement Program (APMA) under IRS's LB&I.

- Team Leader and Economist

- Develop, negotiate, and defend the US position on international double tax disputes (under Competent Authority proceedings) and Advanced Pricing Agreements (APAs).

- Conduct on-going negotiations with foreign tax authorities, US taxpayers, and their representatives.

- Cases cover cross-border transactions with US tax treaty partners, such as: Canada, Mexico, Japan, Korea, Switzerland, Germany, Sweden, United Kingdom, Italy, and Australia.

- Experience with taxpayers in: automobile, pharmaceutical, medical devices, retail, luxury goods, transportation, tourism, mining, contract manufacturing, distribution, chemicals, lumber, electronics, and financial services industries.

- Execute economic analyses: profit-split and cost-allocation models; and finance and treasury related structures.

- Participated in client interviews to gather data and company information to draft transfer pricing planning and documentations reports and APA submissions.

- Conducted economic analyses including: review of client data, development and execution of headquarter cost allocation models, intangible property valuations, and cost sharing arrangements.

- Gained experience in various global industries ranging from cosmetics, apparel, retail, hospitality, healthcare, telecommunication, heavy construction, trading, banking and investment, to oil and gas industries.

- Managed client relationships including drafting of statements of work, proposals and work plans, and management of billing/invoicing and collections processes.

- Assisted with practice development: created internal report templates and automated Excel templates for conducting comparable searches; assisted in training new staff and organizing training material.