Provided analyses in IRS tax dispute

We were engaged by outside counsel to assist them as accounting experts in the representation of their client in a disputes with the IRS that was resolved in the IRS Administrative Appeals process.  The disputes related to the IRS’s assertion that the company’s international transfer pricing policies resulted in insufficient income being recorded in the United States.  The cases spanned a five year year period dating back to 2003.  We performed numerous analyses, including preparing various worldwide product line income statements and constructing a database of all intercompany and third party sales transactions over the seven year period. Our work was presented to management and incorporated into counsel’s negotiations with the IRS.