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.
Transfer Pricing: 2022 in review
Our work during 2022 spanned from assisting start-up companies expanding abroad for the first time to advising large multinationals on multibillion-dollar...