David J. Canale is a senior manager in Ernst & Young’s National Tax Department in Washington, D.C. where he specializes in representing multinational corporations on transfer pricing matters.  David has led a number of transfer pricing projects, including audit dispute resolution, Advance Pricing Agreements (“APAs”), competent authority matters, and transfer pricing planning and studies.  Prior to joining the firm, David served as a Senior Attorney and Team Leader at the IRS’s APA Program in the Office of Associate Chief Counsel (International). David was an Acting APA Branch Chief and also served as the Program’s Coordinator for all bilateral APAs with Canada.  He developed strategies and coordinated with the U.S. Competent Authority in negotiating bilateral APAs with treaty partners including Japan, Canada, Mexico, U.K., Netherlands and Belgium. David is the principal author of IRS Notices 98-10 and 98-65, which provide special procedures for small business taxpayer and small transaction APAs. David is a Vice Chair of the Transfer Pricing Committee in the American Bar Association’s Section of Taxation.  He is a frequent speaker on transfer pricing and has coauthored BNA’s Tax Practice Series Analysis on Transfer Pricing, as well as several articles on transfer pricing issues.  David has an LL.M. (Taxation) from Georgetown University Law Center, a J.D. from Washington College of Law, American University and a B.A. from the University of Dayton.