CRA was retained by counsel of European subsidiaries of Nortel in simultaneous bankruptcy proceedings in the U.S. 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.
US Tax Court favors unspecified method to determine royalty rate
The first US transfer pricing court decision of 2022 was published on Thursday, August 18, 2022, specifically Medtronic, Inc. and Consolidated Subsidiaries v....