Transfer Pricing Solution for Your Inbound Transactions
It is so much more than just another value chain analysis.
Trusted by Colleagues
Our tax partner advises domestic and foreign firms.
Let Us Hear!
We specialize in complex cases.
We Dig and Search to Bring You an Answer.
We dig deep and search far to bring a well-thought-out answer to your tax problem. We reach out and connect with taxing authorities – from the city hall up to rule-writing attorneys at the US Treasury Department – to provide you with accurate interpretations of tax rules.

Overview of Services

  1. Inbound Transfer Pricing Study

    Our transfer pricing reports perform in-depth analysis of an MNE’s activities across the value chain and its market position in the US market, as well as requisite functional/risk analysis, to determine what competitive advantages/significant intangible assets the group utilizes in its US operations and to what extent the group’s US affiliate has contributed to the development thereof. In the inbound transfer pricing context, MNEs are always confronted with whether their US affiliate is allowed to operate at a loss and, if not, how profitable it needs to be. In delivering our transfer pricing reports, we spare no efforts to address such questions with confidence.
    Koshi Kawamura, tax partner of our firm, with more than fifteen years of practice in US and international tax matters, is the main writer for our TP-related services. With expertise encompassing well beyond transfer pricing, he serves clients with versatile advice on cross-border tax issues.

  2. Cross-Border Tax Compliance and Consulting for Businesses

    We provide tax services related to a wide-range of issues in the cross-border business context including, for example, expanding into the US market, reorganizing US affiliates, the PE regime, the FIRPTA regime, and IRC Sec 367 compliance. In collaboration with outside professionals, we also provide tax consulting in specialty areas, such as cost segregation, the Section 41 research credit, and other Federal and state tax credits.

  3. Cross-Border Tax Compliance and Consulting for Individuals

    We provide tax services related to difficult-to-comply issues faced by individuals engaging in cross-border transactions, such as IRC Sec 1291 funds, tax filing by individuals paying tax at the corporate rate under IRC Sec 962, information reporting required for foreign grantor trusts, and estate tax returns claiming benefits under a death tax treaty, to name a few.