J. David Varley, J.D., LL.M., is Acting Director of Transfer Pricing Operations (TPO) in the IRS Large Business and International (LB&I) Division. In this role, Mr. Varley oversees the Transfer Pricing Practice (TPP), the Advance Pricing and Mutual Agreement (APMA) program, and the Income Shifting International Practice Network (IPN). Before assuming his current role, Mr. Varley served as the Acting Assistant Deputy Commissioner, International responsible for many aspects of treaty administration, including assisting in the U.S. Competent Authority's implementation of FATCA, treaty assistance and interpretation, coordination of certification programs for obtaining treaty benefits, and supporting the Treasury Department in bi-lateral Treaty and TIEA negotiations. Mr. Varley has served as the IRS delegate to OECD Committee on Fiscal Affairs Working Parties 1 (model treaty), 6 (transfer pricing) and 10 (exchange of information). He also has extensive and broad experience within the IRS and its Office of Chief Counsel. Prior to his current position, he was a staff attorney to the IRS Deputy Commissioner for Services and Enforcement, Senior Counsel in Branch 7 of the IRS Office of Associate Chief Counsel (International), and senior team leader in the IRS Advance Pricing Agreement Program.