CRA resolved an issue at Appeals relating to management fees for a Silicon Valley client. At issue was the beneficial allocation of expenses and the measurement of stock-based compensation. Rebel Curd successfully argued that the client’s beneficial allocation percentage was the most objective measure and that the client maintained sufficient books and records for the use of the fair value method for the inclusion of stock-based compensation. The case was resolved with zero adjustment.
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...