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Craig Sharon

Craig Sharon


Washington, DC, USA

Craig Sharon is a member of Ernst & Young LLP’s National Transfer Pricing Office.  He is based in Washington, D.C, but spends considerable time on the west coast. 

Craig specializes in all aspects of transfer pricing planning, compliance, and controversy and has particularly deep experience with advance pricing agreements (APAs) and competent authority proceedings.  Prior to joining Ernst & Young LLP in May 2013, Craig served as the IRS APA director from 2008-11.  As APA director, Craig was a member of the senior executive team within the IRS Office of Associate Chief Counsel (International) (ACCI), and in his last year with the IRS, Craig was intimately involved in the development of the restructuring plan that led to the creation of the IRS Large Business & International (LB&I) Division and the merged Advance Pricing Agreement and Mutual Assistance (APMA) Program.

Before becoming APA director, Craig served as an APA Special Counsel and as APA deputy director from 2005-08.  In these roles, he functioned, among other things, as an APA team leader on individual cases and as the coordinator of the APA program’s pharmaceutical and medical device industry group and the automobile and automobile parts industry group.  
Since leaving the IRS, Craig has advised taxpayers on a wide variety of transfer pricing and related international tax issues.  As a sampling of matters, Craig has been involved in the planning and execution of principal restructurings and intellectual property migrations, been retained to assess the transfer pricing risks associated with other particularly complex intercompany transactions, engaged in audit defense, and represented various companies before the APA program and in competent authority proceedings.  Craig has been involved with transfer pricing for more than 20 years.

Craig received his B.A. in Economics from the University of Idaho and his J.D. from Georgetown University Law Center.  He was an adjunct transfer pricing professor in the graduate tax program at Georgetown law from 2006-2012.  Craig is also a frequent writer and speaker on transfer pricing and related international tax issues. 


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