Transfer Pricing Amid COVID-19: Trends, Developments and Practical Guide

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.

Jamie Eagan is the Vice President of Product Management - Tax at insightsoftware. Jamie has over 20 years of experience in helping companies achieve value in their finance and tax solutions through keeping abreast of trends in technology and business. Critical to this success is his ability to bridge the gap between business owner/user and the technology solutions they employ.  Today he leads insightsoftware’s suite of tax focused solutions globally, combining information from customers, partners, revenue authorities, and market trends into an evolving strategic asset for the Tax Organization, continually driving improvements in speed, accuracy and productivity.

David Hutchings, a principal in The Brattle Group’s Toronto office, specializes in conducting economic analysis in complex tax, securities, and antitrust matters. Having assisted experts and attorneys for both taxpayers and taxing authorities, he has extensive experience in tax disputes and transfer pricing matters. He testifies, supports experts, and leads case teams in analyzing and developing economic and financial evidence to support attorneys. Among his experience, Mr. Hutchings has focused on developing innovative economic analyses to assess the best method for transfer pricing, assessing the profitability of transactions, and investigating the business purpose doctrine.

Michael Cragg, a principal at and chairman of The Brattle Group based in Boston and Toronto, has extensive consulting, research, and expert witness experience in complex tax, antitrust, and commercial damages matters. He has assisted corporations, the U.S. Department of Justice, and the Internal Revenue Service in developing economic and financial testimony in a variety of litigation. Dr. Cragg recently played a key role in the closely watched case regarding the government's treatment of AIG, as well as in the highly-publicized Long Term Capital Management litigation and Eaton’s and Glaxo’s recent transfer pricing disputes.