Contract analysis
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Contract analysis / email-cross-to-whitfield-status-update-20220815.eml
email-cross-to-whitfield-status-update-20220815.eml
High · 0
Medium · 1
Standard · 0
1. A comparable uncontrolled transaction (CUT) analysis for the legacy IP royalty rate;
1. A comparable uncontrolled transaction (CUT) analysis for the legacy IP royalty rate;
2. A comparable profits method / transactional net margin method (CPM/TNMM) analysis of PB
2. A comparable profits method / transactional net margin method (CPM/TNMM) analysis of PBI's operating margins; and
3. An income-method / Discounted cash flow revaluation of the PCT.
3. An income-method / Discounted cash flow revaluation of the PCT. Initial data packages have been transmitted to Whitmore under the Kovel arrangement, and all communications are being routed through Calderwood & Harkness to preserve privilege. **Coordination with Thornbury & Keogh (Dublin)** Leila Nazari has been coordinating with Ciarán Thornbury at T&K on Irish-side documentation, including PBI's Irish Revenue fil
1. The adequacy of the PCT payment;
1. The adequacy of the PCT payment;
2. The cost-sharing ratios and the reasonably anticipated benefits methodology;
2. The cost-sharing ratios and the reasonably anticipated benefits methodology;
3. The legacy IP royalty rate; and
3. The legacy IP royalty rate; and
4. PBI's economic substance.
Medium
⚑ Confidentiality undertaking
4. PBI's economic substance. We have confirmed that an IRS economist, Dr. Alan Washburne from the IRS Transfer Pricing Practice, is assigned to the case and will be conducting his own independent economic analysis. IRS Office of Chief Counsel Attorney-Advisor Franklin Rosario is also assigned. None of this is unexpected, but it does confirm that the Service is taking a thorough approach. **Upcoming Deadlines and Acti