Audit, appeals, and litigation consulting

Overview
  • Rebutted the transfer pricing analyses of foreign taxing authorities on behalf of a global automobile manufacturer with international assembly and distribution operations. Analyses addressed intercompany purchases and sales of vehicles, parts and accessories, and various components, as well as payments for services and technology royalties.
  • Assisted a major oil and gas equipment and services company in IRS Appeals proceedings regarding a proposed adjustment to intercompany lease payments between related party rig owners and operating companies. Rebutted IRS transfer pricing methodology with corroborative analyses, including profit split and ROA analyses, and rebuttal analysis regarding intangibles and allocations of risks and investments.
  • Managed the litigation support team in GlaxoSmithKline Holdings (Americas) Inc. v. Commissioner. Supported expert testimony related to the value of the sales and marketing activities of a large pharmaceutical company.
  • Conducted economic analysis refuting an IRS audit position that assessed a taxable income adjustment on a major US-based medical products manufacturer. Conducted alternative analyses and assisted in developing the taxpayer position. Participated in negotiated settlement meetings with the IRS that significantly reduced the taxable income adjustment.
  • Extensive audit/controversy experience including audits of Japanese consumer and computer products manufacturers and telecommunications equipment manufacturers. Our experience in audit proceedings includes numerous IRS meetings, Advance Pricing Agreement request meetings to pursue rollback strategies, memo submissions to the IRS, and managing IDR responses.