Our transfer pricing successes:

  • Successfully defended multinational taxpayers against IRS economist and international examiner transfer pricing attacks, avoiding all adjustments and penalties.
  • Developed in-house comparables transfer pricing strategies for our clients, avoiding the need for the company to rely on public databases – and database fees.
  • Substantiated reinvoicing activities in a tax haven relationship between two high-tax jurisdictions. Successfully substantiated DISC – FISC subsidiary structure to substantiate FISC transfer pricing activities.
  • Successfully defended foreign-based multinational taxpayers against IRS attempts to restructure SIC/NAICS categorization, avoiding all adjustments and penalties.
  • Successfully defended major multinational corporations against IRS documentation claims, avoiding all adjustments and penalties.

What we are doing now in transfer pricing:

  • Structuring Singapore/US coordinating service arrangements while making use of Singapore’s loan safe haven transfer pricing provisions.
  • Structuring transfer pricing for offshore intangible licensing companies and structuring a royalty fee arrangement from a US subsidiary to its foreign parent.
  • Analyzing cost center alternatives as part of a taxpayer’s transfer pricing cost structure, all being part of globally consistent pricing.
  • Developing comparative services approaches for professional services companies.
  • Structuring agency relationships to take advantage of the independent agency - dependent agency permanent establishment tax disparity.


Feinschreiber & Associates
Robert Feinschreiber & Margaret Kent

1121 Crandon Blvd. F301
Key Biscayne, FL 33149
Primary Phone: 305.361.5800
or 305.505.9200
Fax: 305.365.2276
multijur@aol.com
www.transferpricingconsortium.com
www.ExportDISC.com