Transfer Pricing Regulation in the 2020 Landscape: Maximizing Opportunities and Overcoming Challenges

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. 

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.