Transfer Pricing: Avoiding Financial Risks and Dealing with Tax Consequences

Ms. Mert-Beydilli is a Vice President in NERA's Transfer Pricing Practice. Her areas of expertise are developing and defending effective arm's length transfer pricing strategies for multinational companies. She has extensive experience designing and analyzing intercompany transfer pricing policies and valuation of intangible and intellectual property. Ms. Mert-Beydilli has developed expertise in designing pricing methodologies through the use of value chain analysis, determining appropriate intercompany prices for tangible goods and intercompany services as well as royalties, effective implementation of profit split methods, negotiating and implementing Advance Pricing Agreements with tax authorities, and supporting clients in tax controversy situations. She has advised multinational corporations in a variety of industries, including clients in the automotive, construction, and industrial machinery, information technology services, medical equipment, power generation, money transfer, cosmetics, consumer products, and multilevel marketing industries.

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Dr. Korenko is an experienced expert in the application of economics, finance and econometrics to numerous areas including transfer pricing, litigation and complex business matters. In conducting transfer pricing studies, Dr. Korenko has used economic, accounting, financial, and statistical analyses to identify arm's-length prices consistent with U.S. and foreign tax guidelines for intangible property, tangible property, and services. His experience spans a variety of industries, including financial services, pharmaceuticals, computer hardware and software, chemicals, automotive, and others.He has published on topics relating to intellectual property, transfer pricing, and public policy issues and has presented on issues in these areas to a variety of audiences. His work on intellectual property protection in developing countries has been translated into Spanish and distributed in South America, and he has presented at international conferences in Mexico and Brazil.

Michelle has significant experience advising clients on transfer pricing and valuation matters,  including transfer pricing documentation preparation, ASC 740 (FIN 48) recognition and measurement analyses, advanced pricing agreements, cost-sharing analyses, buy-in valuations, supply chain restructuring and tangible and intangible transfer pricing policy development. Michelle has assisted numerous clients on revamping their documentation and compliance processes to become more efficient and effective given today's global audit practices. In addition, Michelle has significant experience managing local teams across the globe to harmonize companies' transfer pricing policies and coordinate global documentation in numerous countries.

Michelle led the development of Duff & Phelps' ASC 740 (FIN 48) service line for transfer pricing and pioneered several thought leadership publications. She is an award-winning speaker and has presented at numerous conferences and seminars regarding transfer pricing issues. She served as co-editor of Wolter Kluwer's Guide to International Transfer Pricing: Law, Compliance and Tax Planning Strategies, and co-authored the BNA Tax Management Portfolio on ASC 740-10 (FIN 48) (published 2012). Michelle also oversaw Ceteris' transfer pricing team's US operations and was responsible for quality and training of the company's US transfer pricing practice. Earlier in her career, Michelle was part of Ernst & Young's transfer pricing practice, having spent time in the company's Chicago, San Jose and New York offices.

Michelle obtained her Masters degree in Economics from New York University and a BS in Economics and French from the University of Illinois.

Claire Kennedy provides tax advice on M&A and corporate finance transactions and advises clients on transfer pricing issues in cross-border investments. She also represents clients during tax and transfer pricing audits and appeals and in Competent Authority proceedings. Claire serves on the board of directors of the Bank of Canada, Canada's central bank. 

Claire has spoken at tax and business conferences on tax planning and is a frequent speaker on transfer pricing topics, including migration of IP and tax and customs issues in a global supply chain. Claire was selected as National Reporter for Canada on Services Establishments at the International Fiscal Association's 2012 International Congress. Claire is the Liaison with International Organizations for the International Bar Association's Taxes Committee, dealing with OECD BEPS and transfer pricing initiatives, and is on the Council of the Canadian branch of IFA.