Cal Poly

Orfalea College of Business

David Chamberlain

David Chamberlain

Director, MS Taxation

Office 03-313
Phone 805-756-1280

Associate Professor of Accounting

David Chamberlain

David Chamberlain is an associate professor of Accounting and Tax in the Orfalea College of Business and Director of Cal Poly’s Masters in Taxation program. He joined Cal Poly after a twenty-five-year career as a tax attorney and advisor, working in the Big Four accounting firms in the S.F. Bay Area and in China as well as with IRS Advanced Pricing Agreement program.

An expert in transfer pricing and international tax, Professor Chamberlain is the author of the transfer pricing chapter of the leading treatise Bittker & Lokken’s Federal Taxation of Income, Estates and Gifts. He also 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. Areas of research include taxation of cryptocurrency, valuation of profits-only interests, the commensurate with income standard, base erosion and profit shifting, European State Aid cases and taxation of employee stock options. He has published in the Florida Tax Review, Virginia Tax Review (forthcoming), Tax Notes Federal, Tax Notes International and other influential journals in the field of taxation.

Professor Chamberlain teaches courses in the MS Taxation program in international tax, advanced corporate tax and taxation of high technology. He also teaches federal taxation of individuals at the undergraduate level. He has been voted by students as Outstanding Faculty in MS Taxation.


  • New York University, LL.M. in Taxation (May 1993)
  • Columbia University, J.D. (May 1992), managing editor of Columbia Journal of Transnational Law
  • University of California at Berkeley, B.A.s (May 1985), assistant to the editor of Journal of Chinese Linguistics


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

Tax Treatises

  • Chapter 79 (Transfer Pricing), Bittker & Lokken’s Federal Taxation of Income, Estates and Gifts.
  • A New Dawn for the International Tax System: Evolution from past to future and what role will China play? [with C. Turley and M. Petriccione]
  • Tax Management Portfolio No. 6945, Transfer Pricing Rules and Practice in China [with J. Su and L. Coronado]

Selected Publications

  • Reuven Avi-Yonah, David Chamberlain, Stephen Curtis & Jeffery Kadet, “Commensurate With Income: IRS Nonenforcement Has Cost $1 Trillion,” Tax Notes Federal (May 22, 2023)
  • David Chamberlain, “The Advocate General’s Opinions in the Fiat State Aid Case: Underestimating the Arm’s Length Principle,” European Taxation (November 2022)
  • Rodney Mock, David Chamberlain & Kathryn Kisska-Schulze, “The Zero Value Tax Fantasy,” Virginia Tax Review (Summer 2022)
  • David Chamberlain, “Forking Belief in Cryptocurrency: A Tax Non-Realization Event,” Florida Tax Review (Spring 2021)
  • David Chamberlain, “Apple, State Aid, and Arm’s Length: EU General Court’s Failure of Imagination,” Tax Notes International (August 31, 2020)
  • David Chamberlain, “How the Tax Court Can Account for Risk in Medtronic Transfer Pricing,” Tax Notes Federal (August 24, 2020)
  • David Chamberlain, Rodney Mock & Kathryn Kisska-Schulze, “Disappearing Forks and Magical Airdrops,” Tax Notes Federal (November 4, 2019)
  • Rodney Mock & David Chamberlain, “Section 199A: Job Creator or Tax Giveaway?”, Tax Notes (December 10, 2018)
  • David Chamberlain & Anni Wang, “On the Importance of the Arm’s Length Range in Transfer Pricing,” International Taxation in China 2013-2 (August 2013) [in Chinese]

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