Our practice is dedicated to solving complex transfer pricing issues (including during audits, examinations and Appeals) and regularly consulted upon to advise on matters such as structuring tax efficient cross-border intercompany transactions, establishing and implementing arm’s length prices and related arrangements, transferring of know-how and other intellectual property, preparing contemporaneous documentation, obtaining expert economic analyses and economic reports, and cost sharing arrangements.

 

Our Washington, DC, based practice and frequent contacts with IRS officials at the Office of the Associate Chief Counsel, International, and the Advance Pricing and Mutual Agreement (APMA) Program give us an exceptional ability to assist U.S. and international-based clients to secure Advance Pricing Agreements (APAs) and Competent Authority Assistance under Tax Treaties.

Illustrative engagements include:

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• An IRS examination of an Italian-based multinational  centered on transfer pricing issues. We resolved this case at the examination level with no adjustments to our client’s income as originally reported.
   

• Successfully protesting before the IRS Independent Office of Appeals the proposed transfer pricing adjustments made to the income of a U.S.-based grower and producer of commodities. Our Protest, Rebuttal to Exam’s positions and powerful advocacy convinced the Appeals officer to reverse all of Exam’s proposed transfer pricing adjustments and close the case.
   

• Negotiating and securing Advance Pricing Agreements (APA) including for an international financial institution in connection with controlled foreign exchange (FX) spot and forward transactions
   

• Protesting before the IRS Independent Office of Appeals the proposed transfer pricing adjustments made to the income of a Chinese-based multinational manufacturer and distributor. The IRS Office of Appeals and our client agreed to settle the case at a negligible cost to our client.
   

• Structuring, preparing contemporaneous documentation, and implementing an intercompany transfer of intangible property between related entities followed by a long-term licensing arrangement.
   

• Designing an intercompany transfer pricing program (including preparation of contemporaneous documentation) for a U.S. based tax exempt entity transacting with its wholly-owned for-profit subsidiary.