- Secured the first bilateral advance pricing agreement to cover all of the imports of a U.S. subsidiary of a major Japanese multinational; in addition to specifying the methodology for examining the pricing in the subsequent years, it resolved contentious disputes for six prior open years.
- Represented a U.S. multinational in securing unilateral advance pricing agreements that provided transfer pricing certainty for transactions with its Irish manufacturing subsidiary and European distribution subsidiaries.
- Represented a variety of multinationals based both inside and outside of the United States in securing bilateral advance pricing agreements for transaction flows between the U.S. taxpayer and its affiliates in other countries, including Japan, Germany, Mexico and Canada.
- Persuaded an IRS appeals officer to withdraw the entire $240 million adjustment that the IRS exam team proposed with respect to proprietary technology made available pursuant to the implementation of a cost-sharing agreement between United States and European affiliates.
- Persuaded an IRS appeals officer to withdraw all of the $31 million of adjustments that the IRS examination team had proposed for the U.S. subsidiary of a large Japanese multinational and the accompanying transfer pricing penalty that IRS management had approved.
- Planned the tax-efficient restructuring of U.S. operations and the transfer of the U.S. assets of a Japanese multinational to enable those operations and assets to be included in a newly formed joint-venture corporation that is managed and controlled outside the United States.
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Multinationals facing tax issues, including transfer pricing matters and tax-efficient structuring of cross-border business transactions, turn to Henry for responsive and pragmatic advice. Both the IRS and the OECD have independently consulted Henry on creating systems to facilitate transfer pricing compliance. He understands your business goals, and works to minimize tax liability and risk.