Neal M. Kochman is a member in Caplin & Drysdale's Washington, D.C. office.
ServicesMr. Kochman's practice focuses on international tax planning, taxation of settlements, and bankruptcy tax matters. His experience covers a broad range of international, domestic, and state tax issues associated with transfer pricing, foreign tax credit planning, corporate restructurings, qualified settlement funds, and withholding and reporting.
Mr. Kochman regularly advises clients on tax controversy matters, providing assistance during tax audits and representation in IRS Appeals proceedings, as well as in technical advice and ruling requests to the IRS National Office. He has represented U.S. multinational companies and U.S. subsidiaries of Belgian, German, Swedish and other foreign parents in advance pricing agreement and competent authority negotiations. Representative engagements include:
- Achieving a favorable Appeals settlement for a foreign auto manufacturer in a multi-year transfer pricing case
- Successfully representing 300 plus individuals in refund claims related to taxation of settlement fund distributions
- Developing a transfer pricing policy and negotiating an APA for a foreign financial services company
- Advising a U.S. multinational on intangible valuation, transfer, and cost sharing issues in conjunction with a corporate restructuring
- Representing a settlement fund established in an age discrimination suit with respect to allocation and withholding issues
Prior to joining Caplin & Drysdale, Mr. Kochman spent over 20 years performing quantitative and policy analyses for federal government agencies, which included: conducting econometric and statistical studies and developed cost allocation and pricing models, developing renewable energy research and development plans, and conducting defense acquisition policy studies.
Professional ActivitiesMr. Kochman has written, been a guest lecturer at Georgetown University Law Center, and spoken at professional meetings on a variety of international and general tax topics, including foreign tax credits, transfer pricing, and the research credit.