Cal Poly

Orfalea College of Business

David Chamberlain

David Chamberlain

Office 03-313
Phone 805-756-1280

Assistant Professor of Accounting

David Chamberlain

David Chamberlain is an assistant professor of Accounting and Tax in the Orfalea College of Business. He has over 20 years of tax experience in both consulting and government roles. Chamberlain started his career with Coopers & Lybrand’s San Francisco office in 1993 and then moved to the San Jose office of PricewaterhouseCoopers after the merger in 1998. In those years, he dealt with a broad range of international tax issues while specializing in transfer pricing. In 2003, Chamberlain founded Transfer Pricing Options, where he dealt with the interplay of transfer pricing and accounting rules with respect to stock-based compensation. In 2006, Chamberlain joined the Internal Revenue Service where he was a team leader in the Advanced Pricing Agreement program. In 2011, he joined KPMG in Silicon Valley and transferred to KPMG’s office in Beijing, China, the following year. In 2015, he joined Ernst & Young in Shanghai, China. During his time in China, David specialized in transfer pricing and worked closely with colleagues in a wide range of disciplines.

As an undergraduate in UC Berkeley, David had majored in Linguistics and Oriental Languages and was assistant to the editor of the Journal of Chinese Linguistics. David moved to New York for his legal education, earning his Juris Doctor degree at Columbia University and his Masters in Law, with a specialization in Taxation, at New York University. At Columbia, David was a managing editor of the Columbia Journal of Transnational Law.

Chamberlain co-authored a book providing a broad overview on the history and practice of international taxation worldwide, along with insights on China’s place in that history. David also taught classes at major Chinese universities, including Peking University, Renmin University and Shanghai University of Finance and Economics. David has published in many industry journals, covering topics ranging from China’s localization of the OECD’s base erosion and profit shifting initiative, recent Treasury debt-vs-equity characterization regulations, transfer pricing penalties, R&D cost sharing arrangements and employee stock options.


  • New York University, LL.M. in Taxation (May 1993)
  • Columbia University, J.D. (May 1992)
  • University of California at Berkeley, B.A.s (May 1985)


  • Ernst & Young, Shanghai, Executive Director
  • KPMG, Beijing, Director
  • IRS APA Program, Team Leader
  • Transfer Pricing Options, Founder
  • PricewaterhouseCoopers, San Jose, Director
  • Coopers & Lybrand, San Francisco, Manager

Selected Publications

  • A New Dawn for the International Tax System: Evolution from past to future and what role will China play?, International Bureau of Fiscal Documentation (February 2017) (ISBN: 978-90-8722-390-8) [with C. Turley and M. Petriccione]
  • Tax Management Portfolio No. 6945, Transfer Pricing Rules and Practice in China (forthcoming) [with J. Su and L. Coronado]

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