Howard Berger, Special Counsel for Covington & Burling, advises clients on transfer pricing, other international tax issues, and tax controversy. His practical perspective is based on more than thirty years of experience. He recently served as Senior Adviser to the Director of Transfer Pricing Operations at the Internal Revenue Service, represented the IRS in examinations and before Appeals, and developed cases for litigation. Mr. Berger also was the primary U.S. representative in arbitration proceedings under U.S. tax treaties and represented the U.S. in Competent Authority negotiations. In previous service with the IRS, Mr. Berger was a principal author of U.S. transfer pricing regulations.