In addition to international transfer pricing, we also perform a significant amount of transfer pricing in the following contexts:
We perform transfer pricing analysis of claims in bankruptcy litigation, and have acted as experts in at least three large bankruptcy matters.
State Transfer Pricing
We perform transfer pricing planning, documentation, and controversy support for state transfer pricing matters.
Real Estate Investment Trusts
We perform studies determining the arm’s length pricing for payments made by taxable REIT subsidiaries to parent REITs for rent, interest, and/or similar items.
We perform studies to determine the arm’s length prices for transactions occurring between commonly controlled non-profit and for-profit companies.
Occasionally, intercompany transactions disadvantage a minority interest. We have analyzed transfer pricing arrangements from both the perspective of a parent company, and the minority interest. We have been called upon to settle disputes as part of negotiations surrounding these issues.
Net Smelter Royalties and Mining-related Claims
In the mining sector, it is not uncommon for royalties to be paid to a licensor of a mining claim, based upon the commercial value of the output of a mine. We have assisted licensors, and licensees, in examining whether or not intercompany transfer pricing that affects the calculation of the royalty payments to the unrelated licensor are arm’s length.