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Sahar Zomorodi

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Sahar Zomorodi is a member of the Firm’s North America Tax Practice Group in New York, where she focuses on a broad range of US and international taxation matters, including tax planning and transactions, transfer pricing, and audit defense and controversy for multinational corporations. Ms. Zomorodi has recently spent a year at the Firm's Amsterdam office, where she provided US tax advice to European based clients.
Ms. Zomorodi has over 14 years of experience in transfer pricing in the private sector and the Internal Revenue Service. Prior to joining the Firm, Sahar was an economist and team leader with the IRS's Advance Pricing and Mutual Agreement Program in Washington, DC, where she developed, negotiated, and defended the US position on international double tax disputes (under Competent Authority proceedings) and drafted advance pricing agreements.
Ms. Zomorodi is an active member of the Firm's Pro Bono and Diversity Committees.
In North America

United States: Updates on US’s Competent Authority Arrangements for the Automatic Exchange of Country-by-Country Reports

by 4 Mins Read

The main objective of OECD base erosion and profit shifting (BEPS) Action Item 13 (Transfer Pricing Documentation and Country-by-Country Reporting (CbC Reports)) is to standardize the information provided to tax authorities in order to increase transparency and combat transfer pricing and base erosion risks. One key tool contained in Action 13 to meet this objective is the framework for government-to-government mechanisms to exchange CbC Reports. The framework provides that CbC Reports are automatically exchanged where the relevant jurisdictions execute bilateral competent authority arrangements(CAAs).