Sanford W. Stark focuses on federal tax controversy and litigation. He counsels on a range of complex domestic and international issues, including a substantial emphasis on transfer pricing. Sanford advises clients in various industries and on all aspects of the controversy process, including pre-audit, audit, appeals, Advance Pricing Agreements and Competent Authority (now APMA), and the federal trial and appellate courts. Sanford’s transfer pricing experience includes significant focus on identifying and valuing intangible property, and further includes transfer pricing planning and internal restructurings.
Sanford is a member of the Bloomberg BNA Transfer Pricing Advisory Board, and he teaches “Introduction to Transfer Pricing” as an adjunct professor in the Graduate Tax Program of Georgetown University Law Center. Sanford is the co-author of "Transfer Pricing: Litigation Strategy and Tactics", BNA Tax Management Portfolio, 893 T.M. (2010). Additionally, Sanford frequently speaks on transfer pricing, tax controversy, and litigation topics. He is a member of the American College of Tax Counsel.
Describing him as a “great practitioner whom peers and clients all trust and respect,” and noting his “transfer pricing expertise,” Chambers USA has named Sanford one of the country’s leading tax controversy lawyers since 2007. Clients say he “takes the time to understand us and you really feel he is part of your team. He always does what’s right for the client.” Sanford has also been recognized as a key controversy and transfer pricing partner by Legal 500.
While serving as a trial attorney in the Tax Division of the US Department of Justice, Sanford litigated many tax issues in the federal courts and received the Tax Division’s Outstanding Attorney Award. Previously, he clerked for Judge Peter Hill Beer, US District Court, Eastern District of Louisiana.
Amazon.com v. Commissioner, 148 T.C. No. 8 (Tax Court March 23, 2017) — Transfer pricing: valuation of Cost Share buy-in and related CSA issues (5-week trial)
The Coca-Cola Company v. Commissioner, Tax Court Docket No. 31183-15 (transfer pricing; trial scheduled for March 2018)
Thomas & Betts Corporation v. Commissioner, US Tax Court Docket No. 4120-17 (transfer pricing; petition filed February 2017)
GlaxoSmithKline Holdings (Americas) Inc. v. Commissioner, US Tax Court Docket Nos. 18940-08 and 18941-08 — Debt/equity, OID (full concession by IRS)
GlaxoSmithKline Holdings (Americas) Inc. v. Commissioner, US Tax Court Docket Nos. 5750-04 and 6959-05 — Transfer pricing: US drug sales (largest tax case in US history; settled 2006)
GlaxoSmithKline Holdings (Americas) Inc. v. Commissioner, 117 T.C. 1 (2001) — Transfer pricing: preservation of testimony
kgb v. Commissioner, Tax Court Docket No. 4667-13 (transfer pricing; settled 2017)
US Freightways Corp. v. Commissioner, 270 F.3d 1137 (7th Cir. 2001), rev’g 113 T.C. 329 (1999) — INDOPCO, judicial deference
Duke University School of Law, 1991, Juris Doctor, with High Honors
Yale University, 1988, Bachelor of Arts, Cum Laude
District of Columbia
US Court of Appeals for the District of Columbia Circuit
US Court of Federal Claims
US Tax Court
Clerkship to Judge Peter Hill Beer of the US District Court for the Eastern District of Louisiana (1991 - 1992)
Awards and Affiliations
Member, Practice Group of the Year, Tax, Law360 (2017)
Leading Advisor, Tax Controversy, International Tax Review’s Tax Controversy Leaders Guide (2017)
Ranked, Tax (Washington, DC), Chambers USA (2017)
Ranked, Tax Controversy (Nationwide), Chambers USA (2007–2018)
Recommended, Tax Controversy, The Legal 500 US (2017)
Recognized, Transfer Pricing Advisors, Expert Guides (2015)
Leading Advisor, Tax Controversy, International Tax Review’s Tax Controversy Leaders Guide (2015)
Recognized, Euromoney’s Guide to the World’s Leading Transfer Pricing Advisers (2013)
Vice-Chair, Transfer Pricing Committee, American Bar Association Tax Section (2016–2017)
Recommended, Tax: US taxes: contentious, The Legal 500 US (2018)