Sonal Majmudar

APAs: Multinationals seeking certainty on their most significant intercompany transactions rely on Sonal to guide them through the advance pricing agreement (APA) process with the IRS and foreign tax authorities. At the IRS, she served as a Manager and Team Leader in the Advance Pricing and Mutual Agreement (APMA) program, leading the development and negotiation of complex APAs with treaty partners in Europe, Asia, and North America. She knows how APMA and foreign competent authorities evaluate a case and skillfully navigates the program's complex procedures from pre-filing through final agreement.

Audit and Dispute Resolution: Sonal advises clients facing IRS and foreign audits involving transfer pricing issues, helping them develop strategies that preserve access to competent authority relief and position disputes for efficient resolution. She also resolves double tax cases through the mutual agreement procedure (MAP) under US tax treaties, drawing on her direct experience negotiating MAP cases for the US competent authority.

Transfer Pricing Planning and Advice: Sonal advises multinationals on structuring and documenting intercompany transactions, including services, financial transactions, and transfers of tangible and intangible property, and on drafting intercompany agreements that align with their transfer pricing policies. Drawing on her government experience, she helps clients design positions that are defensible on audit and well suited to future APA or MAP resolution.

Global Perspective: Sonal previously served on the World Bank Group's global tax team, where she advised the G20 Presidency on emerging international tax issues, including taxation of the digital economy. While there, she also trained tax administrations in Latin America, Eastern Europe, Southeast Asia, and Africa, giving her firsthand insight into how emerging-market tax authorities approach transfer pricing as enforcement intensifies worldwide.

Sonal is Vice Chair of the ABA Tax Section's Transfer Pricing Committee, a member of the Business at OECD (BIAC) transfer pricing working group, and a frequent speaker at industry conferences.