Our senior economist Steven Felgran, Ph.D. was a longtime partner with KPMG, where he worked from 1993 to 2013. He then served as a director with AlixPartners until July 2018, when he founded Felgran Economic Consulting LLC. Earlier in his career, Steve worked for Northeastern University and the Federal Reserve Bank of Boston.
Steve holds a Ph.D. in Economics from Yale University and a B.A. in Economics summa cum laude from the University of Pennsylvania.
Steve has been the lead economist for many transfer pricing projects; conducted transfer pricing analyses in connection with IRS, state and foreign audits; managed advance pricing agreements through successful resolution; developed master file and local documentation; led planning and royalty studies; and provided expert services in support of litigation.
Among the high-profile court cases with which Steve has been involved are the Coca-Cola transfer pricing case litigated in U.S. Tax Court and the bankruptcy of telecom provider Nortel Networks litigated in U.S. Bankruptcy Court and the Ontario Superior Court of Justice.
• The Coca-Cola matter involved the appropriate amount of taxes owed in the United States by the Coca-Cola Company during particular years as a result of licensing intellectual property to certain controlled concentrate manufacturers in return for arm’s-length equivalent royalties. Steve was engaged by the Office of the Chief Counsel, Internal Revenue Service. He authored an expert rebuttal report and provided deposition testimony.
• The Nortel Networks matter involved the application of transfer pricing principles to the assessment of claims and the allocation of residual profit or loss related to the development of intellectual property. Steve was engaged by counsel, Willkie Farr & Gallagher on behalf of certain pension claimants, to review Nortel’s residual profit split methodology, calculate claims post-bankruptcy, and opine on an appropriate allocation. He wrote direct and rebuttal reports for the Courts and testified as an expert at trial.
FELGRAN ECONOMIC CONSULTING LLC
“Transfer pricing was a central issue in the parties’ global dispute over how to allocate $7.4 billion in proceeds from the sale of the Nortel Group’s worldwide assets among the group’s members. Your expert opinion was critical to the allocation theory we were advancing.”
Brian O’Connor, Partner, Willkie Farr & Gallagher LLP