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Dr. Zhou is a valuation, corporate finance, and accounting expert with more than 15 years of consulting experience.

He specializes in the application of finance, accounting, and taxation principles in a variety of consulting and litigation settings for financial institutions (banking and insurance) and companies in the utility, energy, and pharmaceutical industries. He often advises clients on investment risk analysis and valuation, regulatory policies in the financial industries, bankruptcies, and tax controversies including multinational corporation’s transfer pricing disputes.

Dr. Zhou has served as a consulting expert in several high-profile securities, bankruptcy, and tax litigation matters and has supported academic experts in various stages of the litigation. He primarily focuses on high-stake transfer pricing disputes, the economic analysis of structured finance transactions, and economic substance tests of complex tax transactions. His most recent experience includes leading Brattle’s support of two experts in Nortel’s ongoing bankruptcy allocation and claims proceedings, valuing complex derivatives in a contract termination dispute for Barclays, and providing economics justification for an unsettled tax position on credit derivatives in Ambac’s bankruptcy resolution.

Representative Engagements
Analysis of reasonable profitability of investments in non-performing loans
On behalf of the government in Broadwood Investment Fund et al. v. U.S.A., assisted a Brattle and two external experts analyzing the reasonable profitability, net of transaction costs, of the taxpayers’ investment in non-performing loans from China and Korea. The case was dismissed on summary judgment in favor of the government.
Tax dispute regarding taxpayer’s refund during financial crisis
Assisted Ambac in its tax dispute with the IRS regarding the taxpayer’s $700 million tax refund during the recent financial crisis. The dispute involved the appropriate taxation of credit derivatives, currently an unsettled area in tax policies and regulation. The case was recently settled.
Analyses of regulatory and tax policies
During the last three years, conducted economic analyses on the U.S. Securities and Exchange Commission’s (SEC’s) proposed regulations of the money market funds (floating net asset values, capital requirement, and redemption holdback), a tax-favored dividend repatriation tax proposal, the extension of U.S. wind production tax credit program, and taxes on reinsurance premiums ceded to offshore affiliates.
Transfer Pricing and Bankruptcy Allocation in Nortel
In Nortel’s bankruptcy allocation and claims proceedings, Dr. Zhou supported an allocation expert and a transfer pricing expert on behalf of Nortel’s UK pension funds. The key issue before the joint U.S. and Canada courts is the allocation of Nortel’s $7.3 billion liquidation proceedings, mostly from patents-related intangible assets, among Nortel’s three primary bankruptcy estates (Canada, U.S., and EMEA). Dr. Zhou led the Brattle team through all phases of the expert reports, deposition, and trial. He also coordinated with UK pension’s actuarial and pension accounting experts on establishing Nortel UK’s claims against the Canadian estate. The allocation decisions were recently issued in our client’s favor.
Publications
Article
Examining the Role of Market Price in Appraisal Part 1
September 10, 2018
Dick Hackbarth and Bin Zhou
Published in Law360
Article
Examining the Role of Market Price in Appraisal Part 2
September 11, 2018
Dirk Hackbarth and Bin Zhou
Published in Law360
Report
The Social and Economic Contributions of the Life Insurance Industry
September 2018
Funded by MetLife, Inc.

A 2016 whitepaper that has been updated to include new statistics through April 2018 discussing the role of life insurance as a critical driver of economic growth that helps provide stability for the U.S. economy while delivering financial protection to millions of American families. 

Report
PJM Cost of New Entry: Combustion Turbines and Combined-Cycle Plants with June 1, 2022 Online Date
April 19, 2018
Samuel A. Newell, Michael Hagerty, Johannes P. Pfeifenberger, Bin Zhou, Emily Shorin, Perry Fitz, Sang H. Gang, Patrick S. Daou, and John Wroble
Prepared for PJM

PJM Interconnection, L.L.C (PJM) retained The Brattle Group and Sargent & Lundy to review key elements of the Reliability Pricing Model (RPM), as required periodically under PJM’s tariff.

Article
Effects of New Tax Law on Capital Structure and Cost of Capital
March 12, 2018
Dirk Hackbarth and Bin Zhou
Published in Tax Notes, Vol. 158, No. 11

Brattle Principal Bin Zhou recently co-authored an article published in Tax Notes about how the Tax Cuts and Jobs Act (TCJA) will affect a company’s capital structure and the after-tax weighted average cost of capital (COC).

Report
The Impact of a Border-Adjustment Tax on the U.S. Insurance Market
November 17, 2017
Michael I. Cragg, Bin Zhou, Jehan deFonseka, and Lawrence Powell
Prepared for the Coalition for Competitive Insurance Rates and funded by the Association of Bermuda Insurers and Reinsurers

A new study co-authored by Brattle economists examines the impact that a Border Adjustment Tax (BAT) could have had on the U.S. insurance market.

Article
Response on Offshore Reinsurance Tax
October 16, 2017
Michael I. Cragg, Jehan deFonseka, Bin Zhou, and Lawrence Powell
Published in Tax Notes
Article
Evaluating the Impact of an Offshore Reinsurance Tax
March 13, 2017
Michael I. Cragg, Jehan deFonseka, Lawrence Powell, and Bin Zhou
Published in Tax Notes, Volume 154, Number 11
Report
The Impact of Offshore Affiliate Reinsurance Tax Proposals on the U.S. Insurance Market: An Updated Economic Analysis
January 23, 2017
Michael I. Cragg, Jehan deFonseka, Bin Zhou, and Lawrence Powell
Published in Tax Notes, Volume 154, Number 11

This is an excerpt from the report titled “The Impact of Offshore Affiliate Reinsurance Tax Proposals on the U.S. Insurance Market,” originally published on January 23, 2017. This excerpt is focused the economic impact of the border adjustment provision contained in the Republican’s Blueprint tax reform proposal.

Report
The Social and Economic Contributions of the Life Insurance Industry
October 11, 2016
Funded by MetLife, Inc.

A whitepaper discussing the role of life insurance as a critical driver of economic growth that helps provide stability for the U.S. economy while delivering financial protection to millions of American families.

Article
The Interaction of Managerial and Tax Transfer Pricing
January 21, 2016
Published in Bloomberg BNA Tax Management Transfer Pricing Report

The authors examine the differences between transfer prices used for tax and for management purposes, emphasizing the need to explain the differences to tax authorities who may question the company’s motives.

Article
The Implications of Transfer Pricing in Bankruptcy
May 29, 2015
Bin Zhou and Steven D. Felgran
Published in Bloomberg BNA
Report
Statistical review of U.S. macronutrient consumption data, 1965-2011: Americans have been following dietary guidelines, coincident with the rise in obesity
May 2015
Evan Cohen, Michael I. Cragg, Bin Zhou, Jehan deFonseka, Melanie Rosenberg, and Adele Hite
Published in the Nutrition journal
Article
Reducing Rate Shocks
June 2013
Published in Public Utilities Fortnightly
Presentation
Utility Accounting and Financial Analysis: The Impact of Regulatory Initiatives on Accounting and Credit Metrics
October 29, 2012
Presented at EUCI, Denver, CO
Presentation
Control Premiums / Minority Discounts Recent Cases and Economic Evidence
October 18, 2012
Presented for The Knowledge Congress Webcast Series
Report
Economic Considerations in Litigation Against the Credit Rating Agencies
April 2012
Bin Zhou and Pavitra Kumar
Published by The Brattle Group, Inc.
Report
Cost of New Entry Estimates For Combustion Turbine and Combined-Cycle Plants in PJM
August 24, 2011
Prepared for PJM Interconnection
Report
Defining Market Manipulation in a Post-REMIT World
June 2011
Published by The Brattle Group, Inc.
Article
The Impact Of HR 3424 On The US Insurance Market
July 22, 2010
Published in Insurance Law360
Article
Risk-Adjusted Damages Calculation in Breach of Contract Disputes: A Case Study
2010
Frank C. Graves, Bin Zhou, Melvin Brosterman, and Quinlan Murphy
Published in Journal of Business Valuation and Economic Loss Analysis
Newsletter
Litigation Facing the Private Equity Industry
2009
Atreya Chakraborty, Bin Zhou, and Michael S. Weisbach
Published by The Brattle Group, Inc.
News & Events
January 16, 2019
Bin Zhou to Participate in The Knowledge Group Webinar on Fraudulent Transfers

Brattle Principal Bin Zhou will participate in The Knowledge Group’s webinar, “Fraudulent Transfers: Cases, Trends, and Updates in the 2019 Minefield,” taking place January 16 from 3:00-5:00 pm (ET).

September 15, 2018
Yvette Austin Smith, Torben Voetmann, and Bin Zhou to Present at ABA Business Law Section Annual Meeting

Brattle Principals Yvette Austin Smith, Torben Voetmann, and Bin Zhou will speak at the American Bar Association (ABA) Business Law Section Annual Meeting, to be held September 13-15 in Austin, TX.

September 12, 2018
Brattle Economist Offers Expert Opinion on the Relevance of Market Price as Appraisal Remedy

Brattle Principal Bin Zhou and Boston University Professor Dirk Hackbarth have authored a two-part paper series for Law360 on the relevance of market price in measuring fair value.

September 05, 2018
The Life Insurance Industry Continues to Drive Economic Growth and Promote Stability, According to an Updated Report by Brattle Economists

Brattle economists have coauthored an updated report from 2016 which found that the life insurance industry has been a critical driver of economic growth and has helped provide stability for the U.S. economy while delivering financial protection to millions of American families. 

July 17, 2018
Bin Zhou to Speak at the NABE Transfer Pricing Symposium

Brattle Principal Bin Zhou will speak at the National Association for Business Economics (NABE) Transfer Pricing Symposium to be held July 17-19, 2018, in Washington, D.C.

March 12, 2018
Bin Zhou Co-authors Article on the Effects of the Tax Cuts and Jobs Act on Capital Structure and Cost of Capital

Brattle Principal Bin Zhou recently co-authored an article published in Tax Notes about how the Tax Cuts and Jobs Act (TCJA) will affect a company’s capital structure and the after-tax weighted average cost of capital (COC).

November 17, 2017
Brattle Economists Study Impact of Reinsurance Taxes on the U.S. Insurance Market

A new study co-authored by Brattle economists examines the impact that a Border Adjustment Tax (BAT) could have had on the U.S. insurance market.

January 23, 2017
Brattle Report Highlights The Economic Impact Of The Offshore Affiliate Reinsurance Tax

A report co-authored by economists at global consulting firm The Brattle Group finds that newly-proposed tax legislation aiming to defer the recognition of affiliated offshore reinsurance for U.S. tax purposes will negatively impact businesses and consumers in the United States.

October 11, 2016
Life Insurance Industry's Patient Capital is a Driver of Economic Growth and Stability, According to Report by Brattle Economists

A report co-authored by Brattle economists finds that the life insurance industry is a critical driver of economic growth that helps provide stability for the U.S. economy while delivering financial protection to millions of American families, including those most vulnerable to falling below the poverty line.

March 01, 2016
Testimony of Brattle Principal Yvette Austin Smith Contributes to Win for United States Steel Corporation in Debt/Equity Classification of Intercompany Debt

The Ontario Superior Court of Justice recently ruled that financing provided by United States Steel Corporation (USS) to its subsidiary U.S. Steel Canada, Inc (USSC) was debt rather than equity.

June 01, 2015
Bin Zhou Co-Authors Bloomberg BNA Article on the Role of Transfer Pricing in Bankruptcy

Brattle principal Bin Zhou recently co-authored an article published in Bloomberg BNA, “The Implications of Transfer Pricing in Bankruptcy,” in which the authors discuss the lessons learned from transfer pricing arrangements featured in the allocation of liquidation proceeds in Nortel’s bankruptcy trials.

May 14, 2015
Brattle Experts Assist in Securing Favorable Outcome for Client in Nortel’s Bankruptcy Allocation Trial

A decision reached by the Courts' regarding the allocation of Nortel's $7.3 billion liquidation proceeds relied heavily on the findings by Brattle experts.

April 23, 2015
Bin Zhou to Present at University of San Diego School of Law’s Third Annual Transfer Pricing Symposium

Brattle principal Bin Zhou will be a panelist at the University of San Diego School of Law’s Third Annual Transfer Pricing Symposium, taking place April 23-24, 2015 in San Diego, CA.

February 23, 2015
Brattle Economists Author Report on Nutrition and the Rise of Obesity in the United States

Economists from The Brattle Group recently completed a study on dietary trends and the rising rates of obesity in the United States. The report finds that Americans are facing a substantial increase in obesity, despite general adherence to the nutrition advice of the American Heart Association and the United States Departments of Agriculture and Health and Human Services.

August 08, 2014
Brattle Consultants Provide Expert Testimony and Litigation Support in Recently-Concluded Nortel Bankruptcy Proceedings

The Brattle Group was retained by counsel for the UK Pension claimants to opine on allocation and claims issues in Nortel’s bankruptcy proceedings. Brattle experts sponsored and supported two testifying experts in recently-concluded trials.

Personal Interests

Bin is a member of a number of professional associations, including the American Economic Association, the American Finance Association, the Western Finance Association, and the National Association for Business Economics.