2450 N Street, NW
Suite 310
Washington, DC 20037

Tel: 202 296 4005
Fax: 202 296 4008

Thomas Horst

Thomas Horst is the founder and Managing Director Emeritus of Horst Frisch Incorporated. His specializations are 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 testified as an expert witness before the U.S., Australian, and Canadian Tax Courts in various 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 also testified several times before the Federal Energy Regulatory Commission, the Regulatory Commission of Alaska, and the California Public Utilities Commission on cost-of-service, income tax allowance and deferred income tax, 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 at Taxecon Associates, Inc. From 1977 until 1981, he was the Director of the International Tax Staff at the U.S. Treasury Department. 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.

Documents Available

  • Resume of Thomas Horst

  • "The TCJA’s Impact on GAAP Effective Tax Rates of Large U.S. Nonfinancial Corporations"
    Tax Notes International , May 27, 20191, 821-841

  • "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

  • "Using Discount Rates to Adjust Transfer Prices Under Long-Term Agreements for Differences in Risk," BNA Transfer Pricing Report, December 22, 2004


Thomas Horst
Phone: 202-296-4005
Fax: 202-296-4008

Thomas Horst