Planning, compliance, and documentation

  • Conducted numerous transfer pricing studies for tax planning, documentation, and audits. Clients include large multinational companies involved in the automotive manufacturing, medical products, computer software/hardware, industrial equipment, retail clothing, food products, tobacco, oil drilling services, package delivery services, shipping, and industrial products industries.
  • For a European-based company, conducted economic analysis of an intercompany lease of an oil production facility operating in the Gulf of Mexico. Applied corroborative analysis of returns to the related parties to the transaction, including internal rate of return analysis through the use of oil production projections.
  • Analyzed a global company’s participation in carbon credit markets, including affiliates regulated under EU-wide cap-and-trade, host country affiliates (UN Clean Development Mechanism), and other related participants in carbon credit development. Evaluated the parties’ investments, risks, roles, and functions (e.g., project development, regulatory approval, operational, and financial intermediary roles). Analyzed carbon emission reduction credit value from primary and secondary markets through current and forward EU allowance market stages.
  • Performed transfer pricing analysis and documentation of intercompany construction and engineering services for a European parent company with US operations. Established arm’s-length returns by using third-party construction contracts to apply an “internal” comparable uncontrolled services price analysis.
  • Prepared analyses and reports used for planning, implementation, and documentation purposes for a major European business restructuring involving the United States, Switzerland, and 20 other jurisdictions. Presented analyses to financial auditors in Switzerland to discuss transfer pricing structure and implications.