Dr. Felgran is an expert in domestic and international transfer pricing and tax authority policy. He has provided litigation support and expert witness testimony in US and Canadian litigation matters regarding transfer pricing, market pricing, value drivers, intellectual property (IP), and profit allocation, and has presented to Internal Revenue Service advance pricing agreement (APA) and appeals panels.
Dr. Felgran has served as an expert in cases such as The Coca-Cola Company & Subs. v. Commissioner of Internal Revenue, a US Tax Court tax and transfer pricing case, and In re: Nortel Networks, Inc., et al, a major multi-jurisdictional bankruptcy case before the US Bankruptcy Court for the District of Delaware and the Ontario Superior Court of Justice.
He has also provided litigation support and written testimony in private antitrust cases. Dr. Felgran has consulted on complex profit allocation disputes involving transfers of tangible products, intangible assets, services, and funds. He has applied his expertise to tax and non-tax matters for corporate planning, IP, royalty rate determination, industry studies, benchmarking, and supply chain analysis. He has published and presented widely on US and international transfer pricing and taxation, on the Organization for Economic Cooperation and Development's (OECD) base erosion and profit shifting project, and on state aid to multinational enterprises. Dr. Felgran was formerly a director of financial advisory services at AlixPartners; a principal and transfer pricing leader at KPMG; a professor at Northeastern University’s College of Business Administration; and an economist at the Federal Reserve Bank of Boston.