Expert Opinion - Tax Controversy

We were engaged by outside counsel to assist them as accounting experts in the representation of their client in a series of disputes with the IRS that were 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 inter-company and third-party sales transactions over the five-year period.