John M. Breen has joined Caplin & Drysdale’s Washington, D.C. office. His practice focuses on international tax issues involving transfer pricing planning and controversies.
Prior to joining Caplin & Drysdale, Mr. Breen was Chief of Branch 6 in the Office of Associate Chief Counsel (International) at the Internal Revenue Service, which has responsibility for transfer pricing matters and related issues. Previously, he served as an attorney-advisor and as Senior Technical Reviewer in the branch. As Branch Chief, Mr. Breen had review responsibility for two major regulation projects under section 482, one involving controlled services and intangible property and the other involving cost sharing arrangements. Mr. Breen also contributed to several initiatives concerning transfer pricing, including as a member of Issue Management Teams concerning cost sharing arrangements and section 936 Exit Strategies.
From 2002-2008, Mr. Breen was a U.S. delegate to Working Party 6 of the Organization of Economic Cooperation and Development (OECD), which develops guidance concerning Article 9 of the OECD Model Tax Convention as well as the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Working Party 6 also works on other projects, such as business restructuring and attribution of profits to permanent establishments.
Mr. Breen’s professional experience also includes nine years at an international trade litigation firm in Washington, D.C., where he represented clients in unfair trade practice proceedings involving office equipment, automotive parts, steel, and other products.
Mr. Breen has been a speaker and panelist on transfer pricing and related international tax issues before professional groups, including the Federal Bar Association, the American Bar Association Section of Taxation, the California State Bar Taxation Section, the George Washington University/IRS Institute on Current Issues in International Taxation, and the Business and Industry Advisory Committee to the OECD.
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