FacultyFaculty/Author Profile

Peter C. Rock

Internal Revenue Service
Senior Manager, APMA Program
San Francisco, CA, USA

Peter C. Rock is a Senior Manager of the new Advance Pricing and Mutual Agreement Program in the Office of Transfer Pricing Operations, Large Business and International Division of the IRS.  He is responsible for transfer pricing and allocation cases arising within the U. S. Competent Authority program.  Mr. Rock primarily manages cases involving Japan and South Africa.

Mr. Rock has extensive and broad experience within the IRS and its Office of Chief Counsel.   Prior to his current position, he was a Branch Chief with the Advance Pricing Program of the Office of Associate Chief Counsel (International); Team Leader with the Advance Pricing Program; and an attorney in the Large and Mid-Size Business Division Counsel, Small Business Self-Employed Division Counsel, and San Francisco District Counsel.

Before joining the Service, Mr. Rock practiced tax law in the private sector.  Mr. Rock has his B.S. in accounting from St. Mary’s College, his J.D. with Distinction from McGeorge School of Law, and his LL.M. in Taxation from the Georgetown University Law Center.  Mr. Rock is a member of the California and Colorado Bars.


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