Expert Testimony

Robert Chicoine has been called upon to testify as an expert due to his tax litigation experience, vast knowledge of IRS practice and procedure and the complexities of the tax code in civil and criminal tax cases.

Richard Ainsworth has developed an expertise in tax and technology at Taxware and ADP. He has written extensively on tax and technology with over 100 articles in various national and international journals.

Case studies include:

• MURPHY v. LYBECK, King County Superior Court (Cause No. 14-2-04367-8 SEA). Testified in court as an expert regarding the tax treatment of partnership allocations.

Tax fraud & technology (enforcement, defense & analysis):

Co-counsel in MTIC, Value Added Tax (VAT) fraud extradition cases:

• In the Matter of: Extradition of Samir Azizi, Complaint for Provisional Arrest with a View Towards Extradition (18 U.S.C. § 3184) 5:14-xr-90282-PSG (March 31, 2014) District Court, N.D. CA
• In the Matter of: Extradition of Mohammad Safdar Gohir, Complaint for Provisional Arrest with a View Towards Extradition (18 U.S.C. § 3184) 2:14-mj-314-CWH (May 4, 2014) District Court, Nevada.

Electronic Sales Suppression Cases (RST fraud):

• State of Washington v. Yu-Ling Wong, King County Superior Court (Case No. 16-1-00179-0).
• State of New Hampshire v. Stylianos “Steve” Asprogiannia, HNSC #216-2017-cr-610, CHG ID# 1369401C
• State of Washington v. Salvador Sahagun, King County Superior Court (Case No. 18-1-00591-1) and State of Washington v. Salvador Sahagun, Snohomish County Superior Court (Case No. 18-1-007004-31)

Independent advisor (private sector) on all aspects of transfer pricing:

• Transfer pricing (planning) – Assisted multiple global manufacturing firms (aerospace; medical device; technology security) develop multi-jurisdictional transfer pricing regime; all policies, documentation, and strategic analysis including anticipation of litigation defense and APA potential.
• Litigation defense – Expert for US/EU transfer pricing disputes with Fortune 500 multinational – resolved in competent authority.
• Expert advisor (public sector) on statutory/regulatory transfer pricing rules.
  • Drafted first Electronic Sales Suppression (ESS) statutes in US, and provided model language for 26 states. Worked closely with draftsmen, appears at legislative hearings advancing law changes.
  • Assisted governments (EU and Asia) on the design and implementation of transfer pricing regimes under OECD rules.
  • Personal advisor to Director General of World Customs Organization on efforts to harmonize WCO and OECD transfer pricing rules with EU VAT.
  • Developed and advanced technology-based sales suppression solutions.
  • Digital Invoice Custom Exchange (DICE) – Rwanda, Kenya, Nigeria, GCC, Fiji, Ontario, Ivory Coast.
• Advisory Boards (VAT & transfer pricing related):
  • BIAC (Business and Industry Advisory Council) – advisor on behalf of US multinational businesses to OECD Working Parties on Transfer Pricing and VAT.
  • USCIB – ICC Customs and Trade Regulation Committee – advisor on harmonization of customs rules with transfer pricing.