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Tax Controversy and Litigation

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Overview

Selected Work

  • 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 IRSIn 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 proceedingsSubmitted 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 PricingConducted 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 DefenseRebutted IRS economists' positions in several IRS audits based on reference to and analysis of published economics research findings.
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