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  • Transfer Pricing and Tax
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  • Testified in US Tax Court on behalf of taxpayers in Wal-Mart v. Commissioner regarding the statistical basis and accuracy of shrinkage accruals. The Court rejected the testimony of the IRS experts and ruled in favor of Wal-Mart.

  • Conducted a study on the implications of allowing the Volumetric Ethanol Excise Tax Credit (VEETC) to expire at the end of 2010. The study examined the VEETC influence on ethanol supply and market price volatility resulting from increased ...

  • Determined the value of loan portfolios for corporate purposes including valuation of auto loan portfolios for a financing company and valuation of corporate loans transferred between entities.

  • Evaluated impact of potential tax changes and implemented reforms on clients’ businesses.

  • Conducted economic analyses to support clients’ related-party pricing. Documented transactions for individual countries and for global core documentation in various industries including transactions for the United States, Canada ...

  • Provided expert testimony on behalf of a major issuer of retail credit cards involved in a confidential tax dispute with the IRS. Analyzed beneficial life of store credit cards, drawing on the company’s point-of-sale data, credit card data ...

  • 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.

  • Led numerous comprehensive transfer pricing economic and regulatory analyses involving intangibles and intellectual property valuation, R&D cost-sharing buy-ins, risk adjustments, statistical sampling and range adjustments ...

  • Provided expert testimony on behalf of the taxpayers on the statistical basis and accuracy of shrinkage accruals in Kroger v. Commissioner. Citing Dr. Bates’ testimony extensively, the Court ruled in favor of Kroger.

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