TRANSFER PRICING PLANNING AND DOCUMENTATION – U.S. AND FOREIGN COUNTRY

  • Planning intercompany charges for: inventory; licensing of patents, trade names and other intangibles; related party services; intercompany financing and other related party transactions
  • Managing and controlling IRS and foreign country tax audits and controversies
  • Performing “functional analysis” – ranging from a single product to a comprehensive study on a company-wide basis
  • Reviewing and managing economic studies and assessing the quality of comparables
  • Reviewing proposed pricing policies and the implementation thereof
  • Advice with respect to the level of “documentation” which is appropriate and identifying the transactions which should be studied and documented.
  • Advice and planning with respect to “cost sharing arrangements” and “contract R&D” agreements and the implementation thereof
  • Drafting and reviewing intercompany contracts, license agreements and other documentation to withstand scrutiny by U.S. and foreign tax authorities
  • Assessing whether “periodic adjustments” should be made to transfer prices and/or financial results
  • Analyzing foreign tax consequences of changes in pricing policies
  • ecommerce transfer pricing
  • Evaluating the benefits of entering into an Advance Pricing Agreement
  • Tax Treaty “Competent Authority” Assistance (U.S. and foreign-to-foreign)
  • State and local tax planning with intangibles