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  • Established value of trademarks, technology, content and other transferred intellectual property.

  • Prepared economic damages analysis regarding chemical manufacturing for leading plastics manufacturer in Dow Chemical Company v. Nova Chemicals Corporation, 2017 FC 637 (Federal Court of Canada). Conducted economic analysis and ...

  • In anticipation of tax controversy and litigation, developed and presented detailed brand royalty valuation analysis for one of the world’s largest hotel multinationals. This analysis included intellectual property discount rate ...

  • 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 ...

  • 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 ...

  • Led APA negotiations to establish royalty rate for use of technology from a related party. Adapted a comparable transaction to match the facts and circumstances of the related-party transactions to resolve business uncertainty.

  • Negotiated appropriate return for a trading company. Established the appropriate rates of return on products purchased from parent and others sold to the parent.

  • 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.

  • Conducted numerous state transfer pricing studies, identified functional and transactional comparable groups and profitability targets, and established arm's length values for brand, technology and know-how intangibles.

  • Conducted economic analysis in support of global documentation study for a leading primary metal producer, including support for master file and US local documentation local file.

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