Neal M. Kochman

Neal M. Kochman is a Member in Caplin & Drysdale's Washington, D.C., office.

Services

Mr. 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.

Highlights

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 Activities

Mr. 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.

Awards & Rankings

• The Legal 500, Recommended, 2017

Recent News

• 18 Caplin & Drysdale Lawyers Recognized in 2017 Legal 500 Ranking, The Legal 500, June 2, 2017
• Worldwide Tax Daily Quotes Neal Kochman: Amazon U.S. Tax Court Trial Gets Underway, Worldwide Tax Daily, November 3, 2014
• Neal Kochman Comments on Amazon Case Challenging IRS Income Method for Valuing Intangibles, Bloomberg BNA, October 30, 2014
• Tax Analysts Quotes Neal Kochman: Auditors Seeking More Information on Global Operations, Tax Analysts, April 30, 2014
• Neal Kochman Comments on Amazon's IRS Dispute, January 15, 2013

Click here for a full list of media coverage.

Speaking Engagements

• Panelist, Transfer Pricing– Inbound and Outbound, Practising Law Institute, September 19, 2017
• Panelist, Transfer Pricing– Inbound and Outbound, Practising Law Institute, July 19, 2017
• Panelist, Basics of International Taxation 2016, Practising Law Institute, September 20, 2016
• Panelist, Basics of International Taxation 2016, Practising Law Institute, July 20, 2016
• Speaker, Transfer Pricing – Inbound and Outbound, Practising Law Institute (PLI) Seminars, Basics of International Taxation 2015, July 22, 2015
• Panelist, BEPS Round Two: Risk and Capital, American Bar Association, 2015 Midyear Meeting, January 30, 2015

Click here for a full list of speaking engagements.

Recent Publications

• "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets," with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 6, 2017
• "IRS Launches Issue Based Corporate Compliance Campaigns," with Mark D. Allison, J. Clark Armitage, Kirsten Burmester, and Niles A. Elber, Global Tax Weekly, February 16, 2017
• "IRS Launches 13 Issue-Based Corporate Compliance Campaigns," with Mark D. Allison, J. Clark Armitage, Kirsten Burmester, and Niles A. Elber, Caplin & Drysdale Client Alert, February 3, 2017
• "The Final OECD BEPS Tome Has Arrived," with H. David Rosenbloom, Patricia Gimbel Lewis, J. Clark Armitage, and Peter A. Barnes, Caplin & Drysdale Client Alert, October 8, 2015
• "Strategic Resets Under the New MAP and APA Revenue Procedures," with Patricia Gimbel Lewis, J. Clark Armitage, and Sae Jin Yoon, Caplin & Drysdale Client Alert, September 23, 2015
• "Transfer Pricing Audits: Flipping the Tested Party," with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Patricia Gimbel Lewis, Wolters Kluwer, August 27, 2015
• "Transfer Pricing Audits: Flipping the Tested Party," with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Mark D. Allison, Caplin & Drysdale Client Alert, August 13, 2015
• "IRS Releases Guidelines for Examining CFC Transactions," with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Mark D. Allison, Caplin & Drysdale Client Alert, July 29, 2015
• "Treasury Proposes Significant Changes to Model Tax Treaty," with H. David Rosenbloom, J. Clark Armitage, and Peter A. Barnes, International Law Office, June 12, 2015
• "Treasury Proposes Significant Changes to U.S. Model Treaty," Global Tax Weekly, June 4, 2015
• "Treasury Proposes Significant Changes to U.S. Model Tax Treaty," with H. David Rosenbloom, J. Clark Armitage, Peter A. Barnes, and Patricia Gimbel Lewis, Caplin & Drysdale Client Alert, May 26, 2015
• "OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns," with Patricia Gimbel Lewis, J. Clark Armitage, and Peter A. Barnes, Global Tax Weekly, November 6, 2014
• "OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns," with J. Clark Armitage and Peter A. Barnes, Caplin & Drysdale Client Alert, September 23, 2014
• "Bold Shift in IRS Approach to Transfer Pricing Controversies," with Patricia Gimbel Lewis, J. Clark Armitage, and Peter A. Barnes, Caplin & Drysdale Client Alert, February 27, 2014
• "Amazon.com v. Commissioner: Veritas Redux?," with Stafford Smiley, Corporate Taxation, August 1, 2013
• "More and More Transfer Pricing Enforcement in Store!," with H. David Rosenbloom and Patricia Gimbel Lewis, Caplin & Drysdale Client Alert, August 6, 2010
• "IRS Launches New "Transfer Pricing Practice" -- Pilot Program Will Select Audit Cases for Scrutiny," with H. David Rosenbloom and Patricia Gimbel Lewis, Caplin & Drysdale Client Alert, May 5, 2010
• "Addressing the Economic Downturn Under Existing Transfer Pricing Methods," Tax Notes International, June 22, 2009
• "Proposed Cost-Sharing Regulations Issued," Practical US/Domestic Tax Strategies, May 1, 2006
• "Proposed Cost-Sharing Regulations Issues," Caplin & Drysdale, January 15, 2006
• "A New Age in Cost Sharing? The IRS Proposed Regulations," Tax Management International Journal, December 9, 2005
• "Tax Alert," with H. David Rosenbloom, Caplin & Drysdale, June 15, 2005
• "Option Wars: Upping the Ante for Cost Sharing Arrangements," with Patricia Gimbel Lewis, Tax Management International Journal, November 8, 2002
• "Deconstructing Section 905(c): An Examination of The Redetermination Rules After TRA 1997," with H. David Rosenbloom, Tax Notes International, April 1, 2002
• "Cost-Sharing Arrangements Come of Age," with Patricia Gimbel Lewis, Tax Management Memorandum, August 28, 2000

Click here for a full list of publications.