John Breen advises multinational corporations on a range of transfer pricing issues, including both planning and controversy matters. As the National Director of Transfer Pricing at Skadden, Arps, his practice focuses on advice concerning advance pricing agreements and other means of preventing double taxation, including remedies under the mutual agreement procedures of income tax treaties.
Prior to joining Skadden, Arps, Mr. Breen was with the Internal Revenue Service’s Office of Chief Counsel for 10 years, where he served in the group with responsibility for cross-border transfer pricing and related issues, including five years as senior technical reviewer and two years as branch chief. In that capacity, he worked on several projects that led to revisions of the Treasury regulations under Section 482, including guidance related to intercompany services and allocation of income from intangibles and guidance concerning cost-sharing arrangements. From 2001 to 2007, he also served as a U.S. delegate to the Organization for Economic Cooperation and Development (OECD) working party that updates and monitors the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. After leaving the Internal Revenue Service and before joining Skadden, Arps in 2010, Mr. Breen was a member of a nationally recognized law firm in Washington, D.C.
Mr. Breen has been a speaker and panelist on transfer pricing topics before industry and private groups, including the American Bar Association’s Section of Taxation (Committee on Transfer Pricing), the George Washington University/Internal Revenue Service Institute on Current Issues in International Taxation and the OECD International Tax Conference.