CRA’s Gene Tien assisted on multiple IP planning matters involving IP transactions related to life sciences, the digital economy, and financial services in Switzerland, the UAE, and several other European jurisdictions.
The CRA Transfer Pricing expert worked with tax planners to design IP valuations that matched the facts and circumstances, and aligned with local tax and transfer pricing considerations.
On an UAE transaction, Dr. Tien and his team developed a valuation strategy and negotiation approach to achieve a favorable position for both the tax authority and the MNE.
On a Swiss transaction, the team worked with local counsel to understand tax authority pressure points and guide a fast-moving onshoring process in light of sensitive historical parent-company IP positions.
On an Irish transaction, the team addressed legal entity tax and transfer pricing implications across the globe to manage knock-on effects in dozens of jurisdictions and twice as many legal entities.
In each instance, Dr. Tien not only designed the IP transfer, but also conducted subsequent reserve analyses, including attest-firm discussions, and in some instances, designed future transfer pricing documentation strategies to limit future exposure.
