Contract analysis

Section 1: Summary of IDR No. 47 Requests For ease of reference and to facilitate the examination team's review, we restate below each sub-item contained in IDR No. 47, as issued on September 8, 2023: (a) Supplemental employee compensation data for PBI personnel based in Dublin, Ireland, for each of the tax years 2017, 2018, 2019, and 2020, including breakdowns of base salary, bonus compensation, and benefits for key

Section 2: Responsive Documents — Employee Compensation Data 2.1 PBI Employee Compensation Summaries (2017–2020) In response to sub-item (a) of IDR No. 47, PPC produces herewith anonymized compensation summaries for all PBI personnel based in Dublin, Ireland, for each of the tax years 2017, 2018, 2019, and 2020. These summaries have been organized by functional area to facilitate the examination team's review and to

Section 3: Responsive Documents — Travel Records 3.1 PBI Employee Travel Records (2017–2020) In response to sub-item (b) of IDR No. 47, PPC produces herewith travel records for PBI employees based in Dublin who traveled during the tax years 2017 through 2020. These records have been compiled from PBI's Concur Travel & Expense system and supplemented with data from PBI's travel management company, Aldermere Services I

Section 4: Responsive Documents — Supplemental Intercompany Service and Management Fee Documentation In response to sub-item (d) of IDR No. 47, PPC has conducted a comprehensive review of its records to determine whether any intercompany service agreements, management fee agreements, or related documentation have not been previously produced in this examination. PPC confirms that all material intercompany service and

Section 5: Responsive Documents — Updated PBI Headcount Reconciliation In response to sub-item (e) of IDR No. 47, PPC produces herewith a year-by-year headcount reconciliation for PBI, covering the period from PBI's date of incorporation on March 15, 2012, through year-end 2020. The reconciliation reflects PBI's total employee headcount at each year-end, broken down by functional department, and provides a comprehens

Section 6: Document Production Log Set forth below is an itemized log of all documents produced in connection with this response to IDR No. 47, including sequential Bates number ranges, document descriptions, document dates, page counts, and custodian or source information: Total Documents Produced: PPC-IDR47-000001 through PPC-IDR47-001893 Total Page Count: 1,893 pages All documents have been produced in the format

Section 7: Privilege Withholdings Notwithstanding the comprehensive production described above, PPC has withheld certain documents responsive to IDR No. 47 on the basis of the attorney-client privilege and/or the work-product doctrine. These documents are protected from disclosure under applicable law, including but not limited to Fed. R. Evid. 501, the common law attorney-client privilege, and the protections afford

Section 8: Reservation of Rights PPC expressly reserves all rights, defenses, objections, and positions available to it under applicable law, including but not limited to the following: (a) PPC reserves the right to supplement, amend, or correct this response and any prior IDR response at any time, including but not limited to the production of additional documents, the correction of any inadvertent errors, and the p

Section 9: Cooperation and Closing PPC has been committed to full and transparent cooperation with the IRS examination team throughout the course of this examination. This response to IDR No. 47 represents PPC's forty-seventh IDR response and the final IDR response in this examination. Over the course of the past sixteen months, PPC has engaged in a comprehensive and good-faith effort to provide all information and d

1. Documents bearing Bates Nos. PPC-IDR47-000001 through PPC-IDR47-001893 (as itemized in Section 6 above)

2. Supplemental Privilege Log entries (3 entries) Bates Number Range | Document Description | Document Date(s) | Pages | Custodian / Source PPC-IDR47-000001 – 000347 | PBI Employee Compensation Summaries by Functional Area (2017–2020) | 2017–2020 | 347 | PBI Human Resources, Dublin PPC-IDR47-000348 – 000512 | Key Personnel Compensation Detail — Named Senior Decision-Makers (2017–2020) | 2017–2020 | 165 | PBI Human Re