FacultyFaculty/Author Profile
David J. Canale

David J. Canale


Washington, DC, USA

David J. Canale is EY’s Global & Americas Leader, Transfer Pricing Controversy Services. He has over 20 years of experience in transfer pricing. Dave advises both US and foreign-based multinational companies on transfer pricing controversy and risk management, planning and structuring. He assists clients with transfer pricing policies, controversy resolution (including audit dispute resolution), Advance Pricing Agreements (APA), Mutual Agreement Procedures (MAP) and monitoring tax treaties and competent authority. Dave works with companies in a variety of industry sectors, including pharmaceutical, medical device, electronics, computer, telecommunications, energy, transportation, entertainment, automotive, heavy manufacturing, food and beverage, consumer goods, apparel, publishing and information services, retail and chemical.

Prior to joining EY, Dave served with the Internal Revenue Service’s APA Program in the Office of Associate Chief Counsel (International). He was acting branch chief for the program and served as program coordinator for all bilateral APAs with Canada. He also developed strategies and coordinated with the US competent authority regarding negotiations with various treaty partners. Dave’s combined IRS and private practice APA and MAP experience includes well over 200 cases, comprising files with Japan, Canada, Mexico, UK, Germany, France, The Netherlands, Switzerland, Belgium, Australia, China, India, Korea and Indonesia.

Dave is past Chair of the Transfer Pricing Committee in the American Bar Association’s Section of Taxation. He now serves as a technical reviewer on government submissions on behalf of the Section. He is a frequent speaker on transfer pricing, guest lectures for Georgetown Law Center’s LL.M. (Taxation) program, and has provided training to the IRS, Chinese Local Tax Bureaus and the Korean NTS on APA and MAP matters.  Dave has co-authored the Bureau of National Affairs’ Tax Practice Series on Transfer Pricing and Portfolio 947-1st, Reporting Requirements Under the Code for International Transactions. In addition, he has authored many articles on transfer pricing issues.

Dave received a B.A., magna cum laude, from the University of Dayton; a J.D. from American University Washington College of Law; and an LL.M. (Taxation) from Georgetown University Law Center.


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