Michael Peggs is a transfer pricing economist with more than 15 years of worldwide experience in transaction planning, dispute resolution, Mutual Agreement Procedure matters, litigation support, and documentation.
Michael advises U.S. parent companies and U.S. subsidiaries of foreign parents on how to reliably use transfer pricing methods to price transactions between controlled or non-arm’s length parties. He advises clients in a number of capacities – transaction planning, business reorganization and restructuring, strategic policy review and periodic monitoring, compliance with documentation requirements, and during transfer pricing controversy and double tax matters.
Clients approach Michael with a question or concern about how a related-party transaction should work, how to manage transfer pricing risk, or how to respond to a tax authority in a dispute. Foreign attorneys seek Michael’s advice on the U.S. transfer pricing aspects of a global transfer pricing policy. Many clients have Big Four accounting firms doing their documentation and general compliance, and approach Michael for a second opinion on a transaction characterization, a transaction term, or when their existing advisors run into roadblocks during a transfer pricing examination or controversy.
Michael’s 20 years of experience working with advanced transfer pricing matters around the world allow him to quickly see both sides of a transaction and the issues in all jurisdictions, cut through the jargon and detail, deliver highly bespoke advice, analysis and arguments, and explain how it all works in plain English (and French). Where clients would rather not disturb a transfer pricing issue, they find that a meeting with Michael (unapologetically E.S.T.J., the opposite of an accountant) can unexpectedly make things appear less dreadful. He’s an economist who knows the law, tax treaties and administrative procedure, and clings fiercely to the assumption that clients operate in the real world within time and budget constraints.
Queen's University – B.A. in Economics, with honors (1997)
Ruchelman P.L.L.C. provides a wide range of tax planning and legal services for foreign companies operating in the U.S., foreign financial institutions operating ...