Extract to table

Transfer pricing analysis must be based on the information and projections that were reasonably available at the time of the controlled transaction

Hindsight bias must be excluded from the PCT valuation, consistent with the regulations and established case law

Question 7: "Didn't the actual performance of the IP exceed your original projections?" Suggested Response: Emphasize that transfer pricing must be evaluated based on the information available at the time of the transaction — in this case, July 1, 2012 — and not with the benefit of hindsight

PPC's FIN 48 Reserve You must not discuss the $62