Tax Advisers - Deloitte

United States
Robert T Cole
Alston & Bird LLP
The Atlantic Building
950 F Street, NW
Washington DC 20004-1404
US
Tel: (1) 202 756 3306
Fax: (1) 202 654 4926
Email: bob.cole@alston.com
Website: www.alston.com
Bob Cole is a member of the firm’s international tax practice group, of which he was the
founding chair, and concentrates his practice on transfer pricing, tax treaties and other
international tax issues for US business operations abroad and foreign business
operations in the US.
Mr Cole served in the US Treasury from 1967 to 1973 and was appointed its first
international tax counsel in 1971. At the Treasury he negotiated tax and other treaties for
the US, developed the US competent authority procedure for resolving issues under tax
treaties, and led the development of the rules for the allocation of expenses in crossborder
situations.
In his transfer pricing and general international tax practice he assists multinationals in
a variety of contexts, including: representation in competent authority proceedings
under tax treaties; representation in securing advance pricing agreements (APAs) from
the IRS and from other countries; the development and contractual implementation of
worldwide transfer-pricing systems; advising on transfer-pricing issues in connection
with mergers and acquisitions and spin-offs; advising and implementing cost sharing
arrangements; advising on the self-compliance and documentation process needed to
avoid transfer-pricing penalties in the US and other countries; counselling with respect
to US and foreign tax audits; representation in other administrative dispute resolution
proceedings; lobbying on regulations, on tax treaties and agreements, and on legislation.
Mr Cole has participated in hiring and training some of the best international tax lawyers
in the country, many of whom continue to work closely with him at Alston & Bird. He
has developed close working arrangements with tax professionals and tax officials in
other counties, enabling him and his colleagues to provide seamless representation on
international transactions.
Mr Cole is the editor and principal author of Practical Guide to US Transfer Pricing
published by Matthew Bender; a co-author of the Tax Management (BNA) Portfolio on
“Income Tax Treaties – Administrative and Competent Authority Aspects”. He is listed
in Who’s Who in America and similar publications.
Mr Cole received a LLB, magna cum laude, in 1956 from Harvard Law School where he
was an editor of the Harvard Law Review; a BS (Econ), in 1953 from the Wharton
School; and an Academic Postgraduate Diploma in Law in 1959 from the London
School of Economics. He is a member of the American College of Tax Counsel, the
Council of the USA Branch of the International Fiscal Association; a past vice-chair of
the Tax Committee of the National Foreign Trade Council and a member of the Tax
Section of the American Bar Association.
He is admitted to practise in the District of Columbia (1972) and New York (1956).
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