A major US retailer was subject to transfer pricing audits by multiple state tax authorities.
The taxpayer required an economist to rebut the various assertions put forth by auditors across different states, such as to disallow, recharacterize, or reprice intercompany transactions between the national principal company and the in-state retail entity.
Rebel Curd provided expert analysis relating to the economic substance of transactions, the characterization of entities, the existence and ownership of intangible property, and the appropriate composition of benchmark analyses. Ms. Curd participated in successful settlement negotiations with state tax auditors.
