Thomas Horst is the founder and a Managing Director of Horst Frisch Incorporated. He specializes in transfer pricing of U.S. and foreign-based multinationals, analyses of the economic substance of complex agreements and transactions, and U.S. Federal Energy Regulatory Commission regulation of oil pipelines.
In addition to advising private- and public-sector clients, Dr. Horst has testified as an expert witness before the U.S. Tax Court in four transfer-pricing cases, a case involving the apportionment of interest expense between foreign and domestic income, and a case addressing the income tax consequences of a complex partnership agreement. He has also testified several times before the FERC on cost-of-service and other regulatory issues involving oil pipelines and in the Superior Court of Justice of Ontario, Canada about the impact of transfer pricing on a Canadian subsidiary's minority shareholders.
Prior to establishing Horst Frisch in 1988, Dr. Horst conducted a similar consulting business at Deloitte Haskins & Sells (now Deloitte and Touche Tohmatsu) and at Taxecon Associates, Inc. He was the Director of the International Tax Staff at the U.S. Treasury Department from 1977 until 1981. Before 1977, he served on the faculty of Harvard University and the Fletcher School of International Law and Diplomacy at Tufts University and was a Research Associate at The Brookings Institution. He has published several books and articles mainly addressing various transfer-pricing and international tax issues. Dr. Horst received his Ph.D. and M.A. in Economics from the University of Rochester and his B.A. from Amherst College.
- Resume of Thomas Horst
- "Using Discount Rates to Adjust Transfer Prices Under Long-Term Agreements for Differences in Risk," BNA Transfer Pricing Report, December 22, 2004
- "Debt Guarantee Fees and the Arm's Length Standard"
Tax Notes International , February 13, 2012
- "How to Determine Tax-Deductible, Debt-Related Costs for a Subsidiary,"
Tax Notes International, May 16, 2011
- "Employee Stock Options and the Xilinx Case,"
Tax Notes International, September 7, 2009, 849-862