Demystifying the Current Landscape of Transfer Pricing: Best Practices Explored

Robin Hart is a Principal within CRA’s Transfer Pricing practice based in the San Francisco Bay Area. Robin is a highly regarded transfer pricing and tax economist with 18 years of experience serving clients in the life sciences, technology, and consumer products sectors. He has assisted taxpayers with their strategic objectives relating to the transfers and licensing of intangible property, alignment of supply chains, the establishment of high-value and shared service centers, and intercompany financing. Focused primarily on innovative Bay Area companies, Robin has executed on cross-border and domestic transactions involving cost-sharing and IP planning, post-acquisition integration, global BEPS alignment, the launch of new digital business models, and business restructurings. Prior to joining CRA, Robin was a Managing Director with Deloitte Tax in San Francisco.

Anna Soubbotina is a Principal within the Transfer Pricing Practice, based in New York. Ms. Soubbotina has guided companies through the life cycle of their controlled transactions: from international expansion to business and regulatory change, through to effective controversy resolution. She has advised Fortune 100 companies on transactions involving intangible, tangible and financial assets, as well as services, effectively balancing local regulatory requirements across over 200 jurisdictions. These companies typically face additional scrutiny and are most actively engaged with tax global authorities. In her current role, Ms. Soubbotina leverages her experience working with Fortune 100 companies to guide clients through business change and disruption, such as an IPO, global supply chain expansion/contraction, market shocks, profitability and cost changes. Companies going through business transformation need to consider the cross functional implications of their transactions. Ms. Soubbotina’s advisory approach allows flexibility to customize every project and team to bridge the gap between regulatory constraints and business needs.

Dr. Margaret McKeehan is an associate at The Brattle Group with concentrated experience working on tax controversy litigation involving economic substance analysis, transfer pricing, valuation, and debt/equity classification. Dr. McKeehan has experience working with the Internal Revenue Service, U.S. Department of Justice, and taxpayers in a wide variety of industries including information technology, healthcare, energy, and insurance sectors. She received her Ph.D. in Economics from Rice University in 2017, where she focused her academic research on both theoretical and empirical issues in capital and personal income taxation. She has published her research in the Public Finance Review, International Tax and Public Finance, and the Review of Economics of the Household.

Mr. Cohen  has extensive experience in finance matters that include landmark decisions on economic substance, structured finance and transfer pricing, including Long-Term Capital Management, GlaxoSmithKline, Eaton, Altria, BB&T, Fifth Third, Pritired, Buyuk, ITS, and Bank of New York. He has also been involved in several high-profile public health investigations for the federal government involving housing conditions, lead violations, and EPA emissions requirements.

He specializes in valuation, damages and financial analysis across a wide range of industries, including financial services, pharmaceuticals and manufacturing. He is a Chartered Financial Analyst (CFA) with two decades of experience in both standard valuation of corporations and assets, and complex valuation of subsidiaries and financial instruments. He has provided testimony in U.S. District Court and the Court of Federal Claims and has been retained by taxpayers and corporations to provide testimony on valuation, economic substance, and damages.