David Ernick is a Principal in the Transfer Pricing Practice of PricewaterhouseCoopers’ (PwC) Washington National Tax Services office. David has extensive experience in the preparation and negotiation of advance pricing agreements (APAs) and ruling requests, and in the management of competent authority matters and transfer pricing disputes. His practice also includes transfer pricing planning and documentation, cost sharing, IP transfers, and tax valuation services. Prior to joining PwC in 2013, David was Associate International Tax Counsel at the U.S. Treasury Department. While at Treasury from 2004-2013, his responsibilities included negotiating tax treaties and trade agreements, drafting regulatory guidance, and advising on legislative matters. David was the principal staff attorney for transfer pricing matters at Treasury, and advised on every significant guidance project in this area released by Treasury and the OECD during his tenure. He was a member of the drafting team and intimately involved with the development of the temporary and final regulations under Section 482 for intercompany services and cost sharing arrangements. He also represented the United States as a delegate to the Organization for Economic Cooperation and Development (OECD) Working Party No. 6 on Transfer Pricing.
David has also clerked at the U.S. Tax Court and the U.S. Court of Appeals for the Eleventh Circuit. He currently serves as an adjunct professor and teaches a course on transfer pricing in the Graduate Tax Program at Georgetown University Law Center. He is also a co-author of the Practising Law Institute’s (PLI) Transfer Pricing Answer Book and a member of both the Bloomberg BNA Transfer Pricing Advisory Board and the Tax Management International Journal’s Panel of Leading International Tax Practitioners.