Mark Nehoray is a senior partner in the Los Angeles office and leads Deloitte Tax LLP’s Transfer Pricing practice for the West region. He has been consistently recognized by International Tax Review as one of the leading tax advisers in the United States and by Euromoney Legal Media Group as one of "The World’s Leading Transfer Pricing Advisers."

With more than 25 years of public accounting and private industry experience, primarily in the international tax and transfer pricing areas, Mark consults with multinational clients on transborder transactions and assists multinational companies with transfer pricing studies. He also played a pivotal role on the team that successfully negotiated Mexico’s first ever transfer pricing ruling.

Mark is the transfer pricing adviser to three of the world’s largest multinationals, and since 1989, he has conducted a significant number of transfer pricing studies in a variety of industries. These projects have included both defensive work with respect to ongoing Internal Revenue Service (IRS) audits and competent authority assistance, as well as planning studies and advanced pricing agreements.

Since 2002, Mark has been the executive producer and the host of the Transfer Pricing Dbriefs program. He is a frequent speaker at U.S. transfer pricing conferences sponsored by CITE, and California Society of Certified Public Accountants. He has also served as a transfer pricing instructor at the firm's various national and international tax training programs. Mark attended the University of Southern California, where he earned his bachelor's degree in business administration and a master's degree in business taxation. His recent publications include:

• "New Services and Intangibles Regulations: IRS Changes the Mix," Transfer Pricing Report (August 2006)
• "Cost Sharing Arrangements in Brazil," Practical Latin American Tax Strategies (November 2005)
• "Thin Capitalization in Mexico," North American Free Trade & Investment Report (November 15, 2005)
• "New Section 482 Services and Modified Intangibles Proposed Regulations," Tax Management Memorandum, Vol. 44 No. 22 p. 443 (November 3, 2003)
• "Negotiating Mexico's First Break-Even Maquiladora APA," Transfer Pricing Report (July 10, 2002)
• "Three Years of Argentine Transfer Pricing: A Practical Perspective," Transfer Pricing Report (February 20, 2002)

Questions? Contact Mark Nehoray.