CRA was retained by counsel of European subsidiaries of Nortel in simultaneous bankruptcy proceedings in the US and Canada. Our work involved determining $2 billion of damages related to transfer pricing issues and the allocation of $7.3 billion of IP sales proceeds between related parties from a transfer pricing perspective. The CRA team worked on all aspects of the bankruptcy litigation from investigating and evaluating complex issues, the expert discovery process, issuing multiple affirmative and rebuttal reports assessing and critiquing the positions of opposing experts, and the preparation for deposition and trial testimony.
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One of the most common analyses in transfer pricing is on the cusp of being overhauled at a global level. This pending change has the potential to impact many...