Transfer Pricing Planning and Documentation

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 audits and foreign country tax 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 amount 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
e-commerce transfer pricing
Evaluating the benefits of entering into an Advance Pricing Agreement or small APA
Tax Treaty "Competent Authority" Assistance
State and local tax planning with intangibles