Showing 1 - 12 of 13 results
In several tax disputes, the South Carolina Department of Revenue (SCDoR) retained David DeRamus to evaluate a number of companies’ transfer pricing policies and to assess whether the companies’ resulting state corporate income tax ...
Established value of trademarks, technology, content and other transferred intellectual property.
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 ...
Established royalty rate for use of technology from a related party.
Prepared various analyses in support of global manufacturers’ compliance with APAs with the Mexican taxing authorities.
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 ...
Established arm’s-length terms for loans among related parties.
Submitted expert report in a transfer pricing dispute before the tax authority of Ecuador (Servicio de Rentas Internas). Report evaluated whether certain related-party transactions were consistent with the arm's length standard and the ...
Submitted expert reports in several transfer pricing disputes before the Mexican tax authority (Servicio de Administración Tributaria). These reports evaluated whether various related-party transactions were consistent with the arm's ...
Assisted global primary metal producer in establishing functional comparable groups and profitability targets in multiple regions.
Defended global structure against proposed IRS adjustments.
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 ...
Showing 1 - 12 of 13 results