Elena is the Director of Transfer Pricing and Valuation Services. She has over 17 years of transfer pricing, valuation, and general quantitative analysis experience, including over 16 years with Mayer Brown. Elena has performed transfer pricing and valuation analyses for purposes of advance pricing agreements (APAs), tax planning, contemporaneous documentation, audit defense, and litigation for clients that range from some of the largest multinational enterprises in the world to privately-held companies in a wide range of industries that include heavy machinery manufacturing, software, oil & gas, automotive manufacturing, distribution, electronics, pharmaceuticals, consumer products, services, shipping, agricultural production, financial institutions and products, leisure travel, and Internet.
Elena has worked with a number of large U.S. and foreign-parent multinational companies on all aspects of their APA requests and negotiations, including an automotive OEM, an industrial conglomerate, an industrial products company, a global services provider, a multinational bank, and a pharmaceutical company, among others. Analyses conducted by Elena have been used to reach agreement with the IRS or other tax authorities at the field examination or appeals levels, and have been employed in successful competent authority negotiations.
Elena has successfully developed innovative solutions to handle a wide variety of complex transfer pricing issues including foreign exchange fluctuation, location savings, and excess manufacturing capacity. Elena has been engaged in numerous projects that involve transfer pricing of intangible property, including the development of royalty rates for licensed intangibles, valuation of intellectual property for purposes of corporate restructuring, and economic modeling of returns on investment for purposes of cost-sharing arrangements.
Mayer Brown was recently named Tax Controversy Team of the Year for the second consecutive year in the Legal 500 United States Awards. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the US edition. The firm is “regularly seen in the most high-profile controversy cases before the US Tax Court” and produced “yet another impressive run of work” in 2014.