CRA’s Rebel Curd represented a large medical device company at IRS Appeals after a drawn-out field audit handled by the taxpayer. The issue related to the return earned by the US distribution operations. The matter resolved at Appeals with zero adjustment to the taxpayer’s tax return position. With CRA’s principled economic analyses based on a detailed mapping of functions and risks to the comparability criteria, statistical analysis of market returns, and the use of primary and secondary profit-level indicators supported the client’s tax return position so solidly that Appeals found that no adjustment was required.
Highlights from 2025 and looking forward to 2026
In the United States, 2025 brought major activity in high profile transfer pricing disputes and reaffirmed how closely transfer pricing, tariffs, and customs...