Evaluating arm’s length prices for intercompany transfers, spin-offs and acquisitions, and tax planning, Edgeworth provides independent expert analyses, valuation, dispute resolution, and documentation to meet our clients’ domestic and international tax requirements.
Our experts apply rigorous economic, accounting, and statistical methods to determine arm’s length prices for goods, services, and intangible property, including spin-off business units, manufacturing and marketing services, and patents and trademarks.
In each case, Edgeworth provides complete, rigorous documentation to meet the relevant transfer pricing or tax requirements, whether for domestic or international authorities. Edgeworth also works with clients, counsel, and other outside advisors to develop potential transactional structures that appropriately weigh relevant benefits and costs to achieve efficient value chain transformation and management. Our experts have transfer pricing experience in numerous industries, including pharmaceuticals, specialty chemicals, consulting services, and vehicles.
Our experts quantify arm’s length prices and prepare documentation consistent with US and foreign tax guidelines for a variety of goods, services, and intangible assets, such as:
- Patents and know-how
- Tangible property
- Manufacturing or assembly services and related functions
- US and local entity valuation
Edgeworth experts, working with tax counsel and advisors, assist clients with a variety of tax planning issues, including:
- Determining buy-out payments for technologies developed under cost-sharing or other development agreements
- Analyzing the tax consequences of licensing or selling intellectual property to affiliates
Edgeworth provides a full range of audit and dispute support for clients dealing with domestic and international tax authorities, including:
- Preparing supplemental information or analyses to assist in discussions and negotiations with tax authorities
- Providing critical evaluations of adjustments proposed by tax authorities
Insights & News
- Border Adjustments in the Destination-Based Cash-Flow Tax: A Bold Proposal With Unanswered QuestionsBloomberg Law Daily Tax Report | 03.08.2017
Dr. George Korenko co-authored this Bloomberg BNA article on "the practical, legal and policy implications" of the GOP's destination-based cash-flow tax proposal.
- Edgeworth Economics | 12.16.2015
In this year’s annual transfer pricing report, Edgeworth provides an overview of the year’s critical regulatory developments and captures the practical state of transfer pricing for intangibles..
- ALM Legal Intelligence | 11.11.2014
This report illuminates key issues in transfer pricing for intangibles and provides practical guidance on how practitioners are executing their transfer pricing strategies.
- Bloomberg BNA | 07.10.2014
In his article in Tax Management’s Transfer Pricing Report, Dr. George Korenko addresses the OECD’s latest draft on intangibles questions the availability and use of CUTs.
- The Intellectual Property Debate: Perspectives from Law, Economics, and Political Economy | 06.01.2006
This chapter, authored by Dr. George Korenko, discusses three general approaches to valuing intangibles.
- Economic Approaches to Intellectual Property Policy, Litigation, and Management | 09.01.2005
Dr. George Korenko explains some issues associated with transfers of intangibles between local and foreign subsidiaries of a multinational company.
- Tax Management | 03.16.2005
Dr. George Korenko published this article in Tax Management's Transfer Pricing Report.
- Event, 05.18.2017
In this DC Bar webinar, Dr. George Korenko will participate on an expert panel discussing key takeaways from Amazon.com, Inc. v. Commissioner.
- Event, 01.12.2016
- Event, 09.16.2015
- Event, 01.30.2015
Dr. George Korenko will participate in a panel at the ABA Section of Taxation Midyear Meeting.
- Event, 10.22.2014
Join us for the "Transfer Pricing for Intangibles: Outlook 2015" breakfast briefing at the Four Seasons Hotel in Washington, D.C. on October 22.
- Event, 09.24.2013
- Press Release, 12.17.2015
Washington, DC - December 17, 2015 - Edgeworth Economics, a leading economic, financial, and quantitative consulting firm, today released Transfer Pricing: Intangible Property, Tangible Profits 2015.
- Press Release, 10.30.2014
Edgeworth Economics and ALM Legal Intelligence released a report examining how transfer pricing practitioners manage and value intangible assets.
- News, 07.10.2014
Dr. George Korenko addresses the issues of comparability and adjustments for potentials CUTs in this recent article.
- News, 12.17.2013
Edgeworth Partner, Dr. George Korenko, served as a panelist for a transfer pricing Webinar on December 16.
- News, 02.06.2012
Senior Vice President Dr. George Korenko discusses the importance of data to multinational companies faced with transfer pricing valuations in the most recent issue of The Edgeworth Box.