Ednaldo Silva has a Ph.D. (Economics) from the University of California at Berkeley. He taught economic development and econometrics at the Graduate Faculty of the New School for Social Research in New York for over eight years (1982-1990). Dr. Silva became senior economic advisor at the IRS Office of Chief Counsel in Washington DC (1990-1993), and was the first economist in the Advance Pricing Agreement (APA) Program. He was a drafter of the U.S. transfer pricing regulations, and introduced the concepts of “comparable profits” method (CPM or TNMM under the OECD Guidelines), “best” method rule, and arm’s length “range”. After the IRS Office of Chief Counsel, Dr. Silva became senior economist at the law firm Shearman & Sterling (1993-2000). He has expertise in transfer pricing and the valuation of capital stock and intangible assets. Dr. Silva was a Fulbright Scholar (1985) and is fluent in Portuguese and Spanish. Dr. Silva formed RoyaltyStat LLC on February 2, 2000.
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