Tax & Trade

MiCRA’s economists have extensive experience applying economics, econometrics, and finance theory to tasks such as damage estimation, asset valuation, transfer pricing, and the evaluation of like products in dumping cases. For example, the market value of an asset (e.g., a manufacturing plant, contract, or going concern) is equal to the present discounted value of its expected future net cash flow. Future net cash flows may be estimated using conventional economic and econometric methods, and finance theory assists in the choice of the appropriate risk-adjusted rate for discounting future cash flows.

In transfer pricing, MiCRA’s economists have been retained in §482 tax matters where the IRS has sought judgments against foreign firms accused of transferring goods to U.S. marketing subsidiaries at prices that exceed the level that would be established through arm’s-length negotiation. We have also been retained to testify in U.S. Tax Court about various economic principles that have arisen in tax litigation, including whether individual items that are sold as part of a block or portfolio have economic value.

In connection with ITC Dumping Proceedings, MiCRA’s economists have been retained to evaluate like products, to comment on the ITC staff’s methodology for calculating underselling margins, and to rebut arguments raised by opposing economists.



Honda Motors, Inc. v. Internal Revenue Service
Yamaha Motor Corp. USA v. Internal Revenue Service
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