CRA’s Gene Tien assisted multiple foreign-parented companies in navigating the complexities of expanded US operations. For the past decade, the relatively attractive tax and macroeconomic environment of the US has become a target for commercial growth. However, the complex and legalistic tax and TP environment makes it difficult to determine the best path forward.
The CRA Transfer Pricing expert led teams to work with companies to develop a phased assessment approach that allowed multinationals to assess the benefits of different IP models, including cost sharing, licensing, and outright transfers.
In one instance, Dr. Tien coordinated multijurisdictional teams and evaluated potential IP approaches for a SaaS company to create a platform for continued US growth.
In another instance, Dr. Tien worked with law firms to triage US tax nexus rules and potential anti-inversion (§7874) considerations to design the most appropriate valuation strategy for balancing multiple EMEA transfer pricing and tax considerations.
These approaches led to successful commercial performance and created a US platform for M&A to counteract low growth in other global markets.
