Broadcast Date: Wednesday, October 07, 2020
from 10:00 am to 12:00 pm (ET)


As the world grapples with the unprecedented economic disruptions brought by the Coronavirus Disease 2019 (COVID-19) pandemic, multinational enterprises (MNEs) in the U.S. and Canada are confronted by the added challenge of maintaining transfer pricing compliance. Most businesses are now forced to adjust their transfer prices, analysis, and documentation and revisit their force majeure clauses to look for alternative means of fulfilling their contract obligations. Thus, creating a profound strain on the operations of MNEs.

Businesses and practitioners must keep themselves abreast of the regulatory developments in this field of regulation. They must also recalibrate their transfer pricing practices in existing supply chains and adopt practical strategies to ensure business continuity amid the crisis.

In a LIVE Webcast, a panel of key thought leaders and professionals assembled by The Knowledge Group will provide an in-depth discussion of the emerging trends, developments, and critical issues in transfer pricing during the COVID-19 crisis. Speakers will also offer practical strategies to overcome drawbacks in this time of uncertainty.

Key topics include:

  • COVID-19 Implications on Transfer Pricing
  • Tax Authority Guidance relating to Pandemic
  • Critical Issues and Red Flags
  • Practical Tips and Strategies
  • What Lies Ahead


Course Level:



Advance Preparation:

Print and review course materials


Method of Presentation:

On-demand Webcast (CLE)



General knowledge of transfer pricing


Course Code:



NY Category of CLE Credit:

Areas of Professional Practice


Total Credits:

2.0 CLE

Speaker Panel:

Jamie Eagan, Vice President of Product Management

Jamie Eagan is the Vice President of Product Management – Tax at insightsoftware. Jamie has over 20 years of experience in helping companies achieve value in their finance and tax solutions through keeping abreast of trends in technology and business. Critical to this success is his ability to bridge the gap between business owner/user and the technology solutions they employ. Today he leads insightsoftware’s suite of tax focused solutions globally, combining information from customers, partners, revenue authorities, and market trends into an evolving strategic asset for the Tax Organization, continually driving improvements in speed, accuracy and productivity.

Robin Hart, Principal, Transfer Pricing Practice
Charles River Associates

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.

David J. Hutchings, Principal
The Brattle Group

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.

Michael I. Cragg, Principal & Chairman
The Brattle Group

Michael Cragg, a principal at and chairman of The Brattle Group based in Boston and Toronto, has extensive consulting, research, and expert witness experience in complex tax, antitrust, and commercial damages matters. He has assisted corporations, the U.S. Department of Justice, and the Internal Revenue Service in developing economic and financial testimony in a variety of litigation. Dr. Cragg recently played a key role in the closely watched case regarding the government’s treatment of AIG, as well as in the highly-publicized Long Term Capital Management litigation and Eaton’s and Glaxo’s recent transfer pricing disputes.



Robin Hart, Principal, Transfer Pricing Practice

Charles River Associates

  • Survey of tax authority pronouncements on Covid-related transfer pricing issues
  • Authority to change TP Policy and Pricing: force majeure and incomplete contracts
  • Impact and Treatment of Subsidies


Jamie Eagan, Vice President of Product Management


  • Transfer Pricing Challenges have existed historically
    1. Data volumes & Granularity
    2. Cadence/visibility
    3. Alignment of forecast data from finance to actuals
  • Exacerbated by Covid
    1. Material changes to actuals and forecast
    2. How to provide guidance amid uncertainty
    3. More frequent updates requested and jurisdictional variances to account for
  • Technology assisting
    1. Being able to do scenarios Best case/worst case
    2. Narrowing range of potential results
    3. Identifying key drivers of material changes.
    4. Goal of staying ahead of potential impacts where possible.


David J. Hutchings, Principal

The Brattle Group

  1. Valuation for transfer pricing purposes is affected by COVID:

    • Structural economic changes from COVID has (or potentially has) changed valuation assumptions and benchmark inputs in the short term and potentially in the long run (e.g., relative valuations and estimation of systemic risk)
    • Valuators will need to apply judgment about whether to adopt a short term or long run perspective


Michael I. Cragg, Principal & Chairman

The Brattle Group

  1. How to consider intangibles in COVID:
    • Face-to-face meetings have been greatly devalued; at a minimum this dramatically changes travel and hospitality and commercial real estate.
    • Any value chain with network and platform intangibles will experience impacts in the face of COVID as participation on the platform is affected (positively or negatively)

Date & Time:

Wednesday, October 07, 2020

10:00 am to 12:00 pm (ET)

Who Should Attend:

  • Transfer Pricing Lawyers
  • Tax Lawyers
  • Transfer Pricing Advisers
  • Transfer Pricing Managers
  • Chief Financial Officers
  • Financial Reporting Officers
  • Financial Management Officers
  • Tax Managers and Directors
  • Financial Auditors
  • International Tax Consultants
  • Accountants



Jamie EaganVice President of Product Management
Robin HartPrincipal, Transfer Pricing Practice
Charles River Associates
David J. HutchingsPrincipal
The Brattle Group
Michael I. CraggPrincipal & Chairman
The Brattle Group



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