Director of Transfer Pricing and Valuation Services

Elena B. Khripounova

International Tax & Transfer Pricing, Tax Controversy & Litigation, Tax


Elena is the Director of Transfer Pricing and Valuation Services. She has over 20 years of transfer pricing, valuation, and general quantitative analysis experience, including 20 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.

Serviços e Indústrias Relacionadas


  • American Institute for Economic Research Great Barrington, MA, Visiting Fellow, Summer 1994; In-absentia Fellowship, Fall 1994

Formação Acadêmica

  • Maxwell School of Citizenship and Public Affairs, Syracuse University, PhD, Economics
    Teaching/Research Assistantship and Tuition Scholarship, 1994-1999
  • Leningrad Trade and Economics Institute, St. Petersburg, Russia, BA with Highest Distinction (summa cum laude) Economics
    Academic scholarship, 1982-1986


  • Inglês
  • Russo


  • Omicron Delta Epsilon (Honor Society in Economics) member since 1994