- Advanced Price Agreement for automotive manufacturer: Advised one of the world’s largest automotive original equipment manufacturers and its multi-advisor teams on economic analysis, regulatory requirements and negotiation strategies for a four-country Advanced Pricing Agreement.
- Spanish unilateral APA: Led APA negotiations to establish royalty rate for use of technology from a related party.
- US Small Business APA: Negotiated appropriate return for a trading company.
- APA compliance in Mexico: Prepared various analyses in support of global manufacturers’ compliance with APAs with the Mexican taxing authorities.
- Bilateral Advanced Pricing Agreement advisory services in meetings with the IRS: In commodity chemicals industry, provided complex bilateral Advanced Pricing Agreement advisory services, supporting client’s novel and complex global intellectual property and manufacturing profit-split economic analysis approach in formal pre-file, opening conference, final negotiation and agreement drafting meetings with the IRS.
- Brand royalty valuation analysis: In anticipation of tax controversy and litigation, developed and presented detailed brand royalty valuation analysis for one of the world’s largest hotel multinationals.
- Dow Chemical Company v. Nova Chemicals Corporation: Prepared economic damages analysis regarding chemical manufacturing for leading plastics manufacturer.
- Foreign tax transfer pricing analyses: Rebutted the transfer pricing analyses of foreign taxing authorities on behalf of a global automobile manufacturer with international assembly and distribution operations.
- Credit card tax dispute: Provided expert testimony on behalf of a major issuer of retail credit cards involved in a confidential tax dispute with the IRS.
- Sports franchise auction: Provided expert report and deposition testimony regarding an auction of a professional sports franchise, working on behalf of the US Department of Justice, Tax Division.
- Wal-Mart v. Commissioner: Testified in US Tax Court on behalf of taxpayers regarding the statistical basis and accuracy of shrinkage accruals.
- Foreign tax dispute proceedings: Submitted expert reports in several transfer pricing disputes before the Mexican tax authority (Servicio de Administración Tributaria).
- Foreign tax dispute proceedings: Submitted expert report in a transfer pricing dispute before the tax authority of Ecuador (Servicio de Rentas Internas).
- Pharmaceutical Industry Transfer Pricing: Conducted economic analysis in support of US-Canada Advanced Pricing Agreement application by major global pharmaceutical company.
- Pharmaceutical Industry Transfer Pricing: In an audit defense project, analyzed manufacturing profitability of a Puerto Rico pharmaceutical manufacturing facility with unique manufacturing know how.
- Transfer Pricing Audit Defense: Rebutted IRS economists' positions in several IRS audits based on reference to and analysis of published economics research findings.