The economists at Precision Economics have analyzed a variety of transfer pricing topics for taxpayers, the Internal Revenue Service, the Australian Taxation Office and the Canada Revenue Agency. Our transfer pricing economists have been engaged in more than 400 assignments in the context of litigation, APAs, FIN 48 review and documentation planning studies. We have presented our findings in court as well as to Appeals, Audit, APA and Fast Track Audit Teams of the IRS.

Precision Economics has been involved in many of the largest transfer price matters in litigation in recent years, where we have been asked to draft expert witness reports and provide oral testimony at trial. In one case, Precision Economics drafted a lead transfer price economic report in the largest transfer pricing dispute and settlement to date. This report on behalf of the Internal Revenue Service resulted in a $3.4 billion settlement to be paid by GlaxoSmithKline. In another case, under engagement of the Australian Taxation Office and the Australian Government Solicitor, Precision Economics provided direct and cross examination testimony concerning an expert witness report in Australia's Administrative Appeals Tribunal in a matter involving Roche Products Pty. Ltd's transfer prices. Precision Economics was also involved in the first major transfer pricing case in the Federal Court of Australia, in which it provided direct and cross examination testimony concerning three expert witness reports it submitted to the Court in a matter involving SNF's transfer prices. In the Tax Court of Canada, Precision Economics testified on its reports involving the intercompany guarantee fees of General Electric Company and the pricing of receivables for McKesson Corporation. In 2010, Precision Economics provided direct and cross examination concerning an expert report in U.S. Tax Court in San Diego, CA in a transfer pricing dispute between the Internal Revenue Service and Weekend Warrior Trailers, Inc.

Our assignments have covered transfer prices for tangible property, intangible property, financial transactions (guarantee fees, intercompany loans, factoring, etc.) and the provision of services. In many cases, these issues have been combined with "round trip" pricing, embedded intangibles, cost sharing, purchase price allocations and profit split analyses. In the United States, many of our larger matters have involved disputes in Cost Sharing Arrangements and Section 936 Conversions. Among those projects, we have focused on buy-in valuations, Section 367 asset valuations, post-936 conversion transfer prices, and so-called "Double Irish" or "Dutch Sandwich" transactions.

Our experience has allowed us to study a wide variety of industries. In recent years, Precision Economics has been heavily engaged as a transfer pricing consultant in the software, pharmaceuticals, medical products, financial services, and automotive industries. When appropriate, we have worked with industry and technical experts to provide guidance on technology and industry practice for computing transfer prices.

Precision Economics has analyzed transfer pricing issues throughout nearly all of the major economies in the world. While the majority of our work has centered on North America, Europe, Australia, and Asia, our assignments have also covered South America, Africa, and the Middle East. These projects have allowed us to work with corporations, tax authorities, and law firms located around the world and to engage affiliates in various countries.

Our economists frequently speak at or chair transfer pricing conferences and publish research articles. The following articles and seminar materials are available by request via email to information@precisionecon.com.

“How Transfer Pricing Disputes are Resolved with Tax Authorities: Lack of Publicly Available Information," Financier Worldwide: Global Reference Guide Corporate Tax 2011, July 2011, pp. 4-6.

“Projected and Actual Profits' Impact on Licensees,” Tax Management Transfer Pricing Report, Vol. 17, No. 11, October 9, 2008, pp. 461-466.

“The Rise of Intangibles: Applying Rules of Thumb to Profit Splits,” Tax Management Transfer Pricing Report, Vol. 17, No. 4, June 19, 2008, pp. 169-171.

"The Economics of Cost Sharing Buy-Ins: Questions and Answers," Tax Management Transfer Pricing Report, Vol. 16, No. 24, April 24, 2008, pp. 950-953.

"Benchmarking Manufacturing or Distribution Entities Against the Profits of Consolidated Companies," Tax Management Transfer Pricing Report, Vol. 13, No. 5, July 7, 2004, pp. 236-237.

"Comparable Profits Method: Accounting for Margin and Volume Effects of Intangibles" Tax Management Transfer Pricing Report, Vol. 10, No. 19, February 6, 2002, pp. 831-834.

"Cost Sharing Buy-Ins" Chapter in Transfer Pricing Handbook, 3rd Edition, and Transfer Pricing International, edited by Robert Feinschreiber, John Wiley & Sons, 2002, pp. 831-833.

"Cost Sharing Buy-Ins" Corporate Business Taxation Monthly, Vol. 3, No. 3, December 2001, pp 26-35.

"Further Thoughts on Cost Sharing Buy-Ins: A Review of the Market Capitalization and Declining Royalty Methods," Tax Management Transfer Pricing Report, Vol. 10, No. 6, July 11, 2001, pp. 195-97.

"Valuing In-Process R&D for Acquisitions: Economic Principles Applied to Accounting Definitions," Tax Management Transfer Pricing Report, Vol. 9, No. 10, September 20, 2000, pp. 323-326.

"Transfer Pricing and Foreign Exchange Risk," Tax Management Transfer Pricing Report, Vol. 8, No. 6, July 14, 1999, pp. 251-256.

"The Cost of Carry: An Inflation Adjustment to Assure Real Profit Margins," Tax Management Transfer Pricing Report, Vol. 7, No. 17, December 28, 1998, pp. 639-643.

"The Effects of Inflation on Cross-Country Profit Comparisons," Tax Management Transfer Pricing Report, Vol. 7, No. 3, June 3, 1998, pp. 77-82.

"Capital Adjustments: A Short Overview," Tax Management Transfer Pricing Report, Vol. 5, No. 19, January 29, 1997, pp. 613-619.

"Three Technical Aspects of Transfer Pricing Practice: Distinguishing Methods, Using Statistical Ranges, and Developing Data Sets," Tax Management Transfer Pricing Report, Vol. 5, No. 4, June 19, 1996, pp. 97-103.

"The Final Transfer Pricing Regulations: The More Things Change, the More they Stay the Same," Tax Notes, Vol. 64, No. 4, July 25, 1994, pp. 507-523.

“Treatment of Intangibles,” Speaker on Transfer Pricing, Networking Seminars Inc., New York, NY, March 26, 2012 (forthcoming).

“Transfer Pricing,” Guest Lecturer at the Georgetown University Law Center, September 22, 2011.

BNA CITE Seminar on U.S. Transfer Pricing Update, Arranging for Intercompany Transfers of Intangible Property, New York, NY, July 18, 2011.

"Double Irish, Dutch Sandwich and Other Current Transfer Pricing Topics," Guest Lecturer at the Georgetown University Law Center, November 4, 2010.

CITE Two-Day Advanced Transfer Pricing Course, Aspects of Transfer Pricing Principles, Washington, DC, June 7-8, 2010.

“Transfer Pricing,” Guest Lecturer at the Georgetown University Law Center, November 5, 2009.

“Economic Aspects of Transfer Pricing Principles,” Speaker, CITE Conference on U.S. Transfer Pricing Planning and Controversies, Houston, Texas, June 8-9, 2009.

“Fundamentals of Transfer Pricing,” Speaker on Transfer Pricing Methods, IIR Seminar, London, UK, October 29, 2008.

“Fundamentals of Transfer Pricing,” Speaker on Transfer Pricing Methods, IIR Seminar, London, UK, June 11, 2008.

“Transfer Pricing,” Guest Lecturer at The George Washington University Law School, March 26, 2008.

“Fundamentals of Transfer Pricing,” Speaker on Transfer Pricing Methods, IIR Seminar, London, UK, January 30, 2008.

“Economists in Transfer Pricing: Intangibles, Audits, and APAs," presented by the Council for International Tax Education. Houston, Texas, October 15, 2007.

IRR Seminar on Transfer Pricing: Fundamentals Understanding the Five Main Methods Used, London, UK, September 19, 2007.

"New IRS Rules for Transfer Pricing of Services," Strafford Publications Teleconference, July 10, 2007.

"New IRS Rules for Transfer Pricing of Services," Strafford Publications Teleconference, May 8, 2007.

Center for International Tax Education Transfer Pricing Program, Washington, DC, April 23 & 24, 2007.

IRR Seminar on Transfer Pricing: Fundamentals Understanding the Five Main Methods Used, London, UK, January 31, 2007.

Infonex Seminar on Transfer Pricing: Best Practices for Managing the Corporate Transfer Pricing Function Understanding the Issues Involved in the Valuation of Intangibles, San Francisco, CA, October 27, 2005.

CITE Seminar on U.S. Transfer Pricing Planning & Controversies Writing an Economic Transfer Pricing Report, New York, NY, August 8, 2005.

National Press Club Conference on "Revenue Matters" Maximizing Revenue, Minimizing Taxpayer Burden, Washington, DC, June 7, 2005.

Infonex Transfer Pricing Roundtable on Best in Class Practices for Companies Intangible Valuation in Transfer Pricing, New York, NY, May 25, 2005.

IIR's Annual Tax Planning for Multinationals Conference International Transfer Pricing Workshop, Conference Chair, London, UK, April 25, 2005.

CITE Seminar on U.S. Transfer Pricing Planning & Controversies The Economics of Transfer Pricing: Independent Arm's Length Analysis, Los Angeles, CA, October 25, 2004.

IIR's Corporate Tax Congress Conference Transfer Pricing: Due Diligence and Risk Review, London, UK, September 29, 2004.

CITE Seminar on U.S. Transfer Pricing Planning & Controversies The Economics of Transfer Pricing: Independent Arm's Length Analysis, New York, NY, August 16, 2004.

IIR's Annual Tax Planning for Multinationals Conference International Transfer Pricing Workshop, Conference Chair, London, UK, April 21, 2004.

CITE Seminar on US Transfer Pricing Economists in Transfer Pricing: Independence, Methodologies, and Case Study, New York, NY, February 23, 2004.

CITE Seminar on US Transfer Pricing Planning & Compliance Economists in Transfer Pricing: Independence, Cost Sharing, and CPM Volume Effects, New York, NY, August 18, 2003.

CITE Seminar on US Transfer Pricing Planning & Compliance Economists in Transfer Pricing: Profit Splits, Volume Effects, Cost Sharing and Real Options, Washington, DC, May 6, 2003.

CITE Seminar on US Transfer Pricing Planning & Compliance Economists in Transfer Pricing: Profit Splits, Volume Effects, Cost Sharing and Real Options, Dallas, TX, March 24, 2003

IRS Seminar Topics in Transfer Pricing and Valuation, Conference Chair, Washington, DC, December 9-10, 2002

CITE Seminar on US Transfer Pricing Planning & Compliance Economists in Transfer Pricing: Cost Sharing and Real Options, September 23, 2002

Valuation of Intangible Property and Cost Sharing Arrangements Seminar Before IRS Northern California Economists, San Francisco, CA, June 25, 2002.

Valuation of Intangible Property and Cost Sharing Arrangements Seminar Before IRS Southeastern Economists, Atlanta, GA, May 10, 2002.

CITE Seminar of U.S. Transfer Pricing and Compliance Pricing Cost Sharing Buy-Ins and Other Intercompany Transfers, New York, NY, November 15-16, 2001.

Atlas Seminar on Intermediate U.S. International Tax Update Pricing Cost Sharing Buy-Ins and Other Intercompany Transfers, Cleveland, OH, November 5, 2001.

Internal Revenue Service Annual Economist Convention Cost Sharing Buy-Ins: Market Capitalization, Declining Royalty, and Other Methods, Washington, DC, July 25, 2001.

Valuation and Finance Principles Applied to Transfer Pricing A presentation to IRS and Treasury Department Economists, Washington, D.C., September 11, 1997.

Some Economic Issues in Transfer Pricing WorldTrade Institute: Tax Aspects of Intercompany Transfer Pricing, New York, NY, November 9-10, 1995.