Contract analysis
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Contract analysis / appeals-conference-attendee-list.docx
appeals-conference-attendee-list.docx
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1. Formal Protest of Penterra Pharmaceuticals Corp. (filed December 22, 2023), with all a
1. Formal Protest of Penterra Pharmaceuticals Corp. (filed December 22, 2023), with all attachments and supporting schedules
2. Exhibit A — PPC/PBI Cost-Sharing Arrangement Agreement (as amended)
2. Exhibit A — PPC/PBI Cost-Sharing Arrangement Agreement (as amended)
3. Exhibit B — PPC/PBI License Agreement for Legacy Intangible Property
3. Exhibit B — PPC/PBI License Agreement for Legacy Intangible Property
4. Exhibit C — Summary of Whitmore Valuation Group CUT Analysis (14 Comparable Agreements
4. Exhibit C — Summary of Whitmore Valuation Group CUT Analysis (14 Comparable Agreements)
5. Exhibit D — Summary of Whitmore Valuation Group CPM/TNMM Benchmarking Study (22 Compar
5. Exhibit D — Summary of Whitmore Valuation Group CPM/TNMM Benchmarking Study (22 Comparable Companies)
6. Exhibit E — Summary of Whitmore Valuation Group PCT Income-Method/DCF Valuation
6. Exhibit E — Summary of Whitmore Valuation Group PCT Income-Method/DCF Valuation
7. Whitmore Valuation Group Economic Reports (complete versions, including appendices and
7. Whitmore Valuation Group Economic Reports (complete versions, including appendices and data sources)
8. PBI Substance Evidence Binder (organizational charts, employee headcount data, board m
8. PBI Substance Evidence Binder (organizational charts, employee headcount data, board minutes, operational activity summaries, functional analyses)
9. Supplemental Legal Authorities (case law, revenue rulings, regulations, OECD Transfer
9. Supplemental Legal Authorities (case law, revenue rulings, regulations, OECD Transfer Pricing Guidelines excerpts)
10. Appeals Conference Document Binder — Table of Contents (master index of all materials
High
⚑ Penalty / liquidated damages
10. Appeals Conference Document Binder — Table of Contents (master index of all materials organized by issue) All materials have been assembled in the Appeals Conference Document Binder and copies will be available for use by the taxpayer's representatives during the conference. A copy of the Formal Protest and all exhibits has previously been transmitted to the Appeals Officer. 5.4 Background Case Reference The foll