|
 Transfer pricing (Advance Pricing Agreement, Examinations, Global Tax Planning)- California Unitary tax (Examinations, Planning)
- Global tax planning (Implementation of global tax minimization, Custom savings)
- Other US GAAP Accounting and Federal Taxation Issues (Contingent liability issue and income tax accounting)
Contributions:
- Bilateral APA (major automotive) : Currency fluctuation analysis, special purpose audit
- Bilateral APA (automotive) : US-Japan APA involving four US entities
- Bilateral APAs (motor vehicle and Small engine) : 2nd US-Japan APA that closed 13 tax years with no adjustment, developed mature market comparable concept, enhanced competition behavior analysis in oligopoly environment
- Renewal of Bilateral APA renewal (motor vehicle) : Developed a new transfer pricing method (Residual Profit Split Method “ RPSM”) including US distribution and manufacturing activities in one analysis
rations in one analysis
- Bilateral APA renewal (car audio) : Successfully developed and utilized RPSM
- APA (major electric/electronic parts) : Successfully concluded with no adjustment by arguing that Mexican operations should be excluded as a non-transfer pricing issue.
- APA (major power tool manufacturer) : Recommended and performed economic analysis for significant non-transfer pricing related losses that helped persuade US & Japan governments to accept significant losses with no adjustment
- Small Taxpayers’ APAs : Successfully helped the taxpayers to conclude the SBT-APA including two travel agency companies and an aircraft parts US supplier company
- Numerous transfer pricing examinations in the US and in Japan in various industries
Publications:
- Articles in “International Taxation”, “ International Legal Strategy”
Seminars:
- Frequent speakers at various seminars in Japan and the US
Others:
- Correlative adjustment, Constructive dividends, year-end adjustment, custom issues, development of RPSM model and development of “Risk-Taker model.”
|
