Tax Controversy & Transfer Pricing
Analysis of Complex Transactions

Complex transactions with associated tax benefits are often challenged under key judicial doctrines such as the economic substance, step transaction, and business purpose doctrines. Brattle has been retained by both tax authorities and taxpayers to provide advice, economic analysis, and expert testimony on economic and financial issues related to these judicial doctrines. We have analyzed the potential for economic profit and evaluated non-tax business purposes associated with a wide variety of transactions including asset sales and purchases, leasing, financing, tracking stock, hedging, derivatives, corporate restructuring and divestitures, and insurance products. We have analyzed transactions conducted by individuals, partnerships and corporate entities.

Representative Engagements: