Brattle | Insights & Events | Tax Controversy & Transfer Pricing https://www.brattle.com/ Tue, 11 Apr 2023 15:31:05 +0000 en-US hourly 1 https://wordpress.org/?v=6.1.1 https://www.brattle.com/wp-content/uploads/2021/05/favicon.png Brattle https://www.brattle.com/ 32 32 The Cancellation of Debt and Tax Strategies to Preserve Value: David Plastino to Discuss at ABI Annual Spring Meeting https://www.brattle.com/insights-events/events/the-cancellation-of-debt-and-tax-strategies-to-preserve-value-david-plastino-to-discuss-at-abi-annual-spring-meeting/ Tue, 11 Apr 2023 15:29:49 +0000 https://www.brattle.com/?p=49981 The post The Cancellation of Debt and Tax Strategies to Preserve Value: David Plastino to Discuss at ABI Annual Spring Meeting appeared first on Brattle.

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Financial Economist Andrew Roper Joins The Brattle Group as Principal https://www.brattle.com/insights-events/news/financial-economist-andrew-roper-joins-the-brattle-group-as-principal/ Mon, 13 Mar 2023 18:53:24 +0000 https://www.brattle.com/?p=49577 The Brattle Group has welcomed Dr. Andrew Roper to its San Francisco office as a Principal in the firm’s Securities Class Actions practice. Dr. Roper is a financial economist specializing in securities litigation, class certification, internal or regulatory investigations, and matters requiring valuation or damage estimates. “With his extensive expertise in securities trading, valuation, and causation, Drew is a […]

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The Brattle Group has welcomed Dr. Andrew Roper to its San Francisco office as a Principal in the firm’s Securities Class Actions practice. Dr. Roper is a financial economist specializing in securities litigation, class certification, internal or regulatory investigations, and matters requiring valuation or damage estimates.

“With his extensive expertise in securities trading, valuation, and causation, Drew is a robust addition to our firm’s Securities team,” said Brattle Interim President & Principal David J. Hutchings. “His testifying experience and ability to help parties understand risk in complex portfolios involving options will be a major asset to Brattle’s clients.”

With more than 15 years of litigation consulting experience at top consultancies, Dr. Roper has served as a testifying expert in several high-profile commercial litigation matters, including as a class action certification expert. He has consulted on matters involving options trading, claims relating to risk management, fixed and variable rate annuities, and more.

Dr. Roper’s consulting experience is supported by a strong background in academia. He has held research and teaching positions focused on corporate finance at the Stanford Law School, the University of Wisconsin-Madison, and Duke University’s Sanford School of Public Policy. His work has been published in several leading economic and financial journals.

“I look forward to continuing to build the Brattle brand in securities litigation,” said Dr. Roper. “With the deep bench of expertise already in place and opportunities to invest going forward, Brattle should be on the top of the short list for clients looking for experienced securities experts that use innovative approaches.”

Before joining Brattle, Dr. Roper founded his own litigation consulting firm Catalyst Economic Consulting, and gained prior experience as an Executive Vice President and a Vice President, respectively, at two global economics consultancies.

To learn more about Dr. Roper, please see his full bio.

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American Finance Association Announces 2022 Recipients of The Brattle Group Prizes in Corporate Finance https://www.brattle.com/insights-events/news/american-finance-association-announces-2022-recipients-of-the-brattle-group-prizes-in-corporate-finance/ Tue, 17 Jan 2023 21:07:55 +0000 https://www.brattle.com/?p=48670 Each year, the Associate Editors of The Journal of Finance – published by the American Finance Association (AFA) – select three winners to receive The Brattle Group Prizes for outstanding papers in corporate finance. The Brattle Group supports this annual award to recognize the importance of excellence in providing groundbreaking analysis and debate on compelling issues facing the […]

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Each year, the Associate Editors of The Journal of Finance – published by the American Finance Association (AFA) – select three winners to receive The Brattle Group Prizes for outstanding papers in corporate finance. The Brattle Group supports this annual award to recognize the importance of excellence in providing groundbreaking analysis and debate on compelling issues facing the corporate finance community.

The winners of the 2022 Brattle Group Prize in Corporate Finance are:

First Prize, $25,000: Andreas Fuster, Paul Goldsmith-Pinkham, Tarun Ramadorai, and Ansgar Walther
Predictably Unequal? The Effects of Machine Learning on Credit Markets
The Journal of Finance, February 2022

Distinguished Paper, $10,000: Asaf Bernstein
Negative Home Equity and Household Labor Supply
The Journal of Finance, December 2021

Distinguished Paper, $10,000: Isaac Hacamo and Kristoph Kleiner
Forced Entrepreneurs
The Journal of Finance, February 2022

The Brattle Group has funded this annual award for more than 20 years. These prizes are presented at the AFA’s annual meeting, and this year’s awards were announced at the AFA’s Annual Meeting 2023, which took place January 6–8 in New Orleans, LA. All papers published in issues of The Journal of Finance from the first five issues of the given year, and December of the previous year, are eligible. We congratulate the winners on their achievements!

View a complete list of past winners

More about the AFA

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Dr. Ara Stepanyan Joins The Brattle Group’s Tax Controversy & Transfer Pricing Practice https://www.brattle.com/insights-events/news/dr-ara-stepanyan-joins-the-brattle-groups-tax-controversy-transfer-pricing-practice/ Mon, 28 Nov 2022 20:40:22 +0000 https://www.brattle.com/?p=48395 The Brattle Group has welcomed Dr. Ara Stepanyan to its Boston office as a Principal in the firm’s Tax Controversy & Transfer Pricing practice. He brings nearly two decades of experience in combining economic analysis and causal data science methods to support clients in strategy, investigations, negotiations, and complex litigation. “We know firsthand from past collaborations that Ara is […]

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The Brattle Group has welcomed Dr. Ara Stepanyan to its Boston office as a Principal in the firm’s Tax Controversy & Transfer Pricing practice. He brings nearly two decades of experience in combining economic analysis and causal data science methods to support clients in strategy, investigations, negotiations, and complex litigation.

“We know firsthand from past collaborations that Ara is a welcome addition to the Tax Controversy & Transfer Pricing practice and our firm more broadly,” said Brattle Interim President & Principal David J. Hutchings. “His creativeness, responsiveness, and depth of analytical rigor when answering difficult questions in transfer pricing and economics – which are becoming more commonplace – will be invaluable to Brattle’s team and our clients.”

Among his transfer pricing experience, Dr. Stepanyan has extensively worked on value chain design, valuation of intangible assets and financial instruments, documentation and audit support, M&A due diligence and transfer pricing risk assessment, advance pricing agreement negotiations, and disputes. He has served as a consulting expert for some of the US’s largest tax and transfer pricing matters, assisting attorneys in all phases of litigation. In addition, Dr. Stepanyan leads teams of economists and data scientists in developing performance improvement solutions rooted in causal inference.

“I am very excited to be joining Brattle’s world-class team during this pivotal time – as tax authorities in the US and around the world are strengthening their transfer pricing enforcement capabilities and investing in data analytics tools for monitoring and risk assessment, the number of transfer pricing audits is expected to continue to increase alongside litigation,” shared Dr. Stepanyan. “I look forward to collaborating with my new colleagues and providing consulting and litigation support services to clients.”

Dr. Stepanyan has taught economics at Rice University, and has written on transfer pricing, valuation, and other topics for leading industry publications such as Tax Notes FederalTax Notes International, and the Journal of the Association of Insolvency & Restructuring Advisors.

Prior to joining Brattle, Dr. Stepanyan was a Principal at a consulting firm focused on economics, strategy, and technology. He previously worked at a global management consultancy and Big 4 accounting firms.

To learn more about Dr. Stepanyan, please see his full bio.

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Hidden Leverage in Real Options: Brattle Consultants Uncover in the Journal of Applied Corporate Finance https://www.brattle.com/insights-events/publications/hidden-leverage-in-real-options-brattle-consultants-uncover-in-the-journal-of-applied-corporate-finance/ Fri, 22 Apr 2022 15:53:09 +0000 https://www.brattle.com/?p=45738 MIT Prof. and Principal Emeritus Stewart C. Myers and Brattle Principal James Read expose the leverage implicit in real options, and explore the implications for financial theory and practice, in the current issue of the Journal of Applied Corporate Finance. Real options are investment opportunities that will be exploited in the future if they become […]

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MIT Prof. and Principal Emeritus Stewart C. Myers and Brattle Principal James Read expose the leverage implicit in real options, and explore the implications for financial theory and practice, in the current issue of the Journal of Applied Corporate Finance.

Real options are investment opportunities that will be exploited in the future if they become sufficiently valuable. The capital expenditure that real-option exercise requires is implicit leverage; it acts like debt because it increases financial risk and because not undertaking investments can be costly.

Real-option leverage does not appear on corporate balance sheets, so observed capital structures of firms that hold real options may provide a distorted view of the debt capacity of the underlying assets.  This implies that estimates of the cost of capital based on observed capital structures of such firms will be biased. And it suggests that capital-structure theories will be difficult to test when real options and hidden leverage are important.

The full article, “Real Options and Hidden Leverage,” can be found below.

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Toby Bishop, Expert on Regulatory Economics and Litigation Matters in the Energy Industry, Joins The Brattle Group as Principal https://www.brattle.com/insights-events/news/toby-bishop-expert-on-regulatory-economics-and-litigation-matters-in-the-energy-industry-joins-the-brattle-group-as-principal/ Thu, 03 Mar 2022 17:39:09 +0000 https://www.brattle.com/?p=45323 The Brattle Group has welcomed Toby Bishop to its Boston office as a Principal with the firm’s Regulatory Economics, Finance & Rates practice. Mr. Bishop brings over 25 years of consulting experience working with the electric and natural gas industries, specializing in regulatory and civil litigation matters. “Toby is a welcome addition to Brattle’s Electricity […]

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The Brattle Group has welcomed Toby Bishop to its Boston office as a Principal with the firm’s Regulatory Economics, Finance & Rates practice. Mr. Bishop brings over 25 years of consulting experience working with the electric and natural gas industries, specializing in regulatory and civil litigation matters.

“Toby is a welcome addition to Brattle’s Electricity group and our firm more broadly,” said Brattle President & Principal David L. Sunding. “With his regulatory expertise and breadth of experience working with electric and natural gas utilities, he will add depth to our firm and be a vital asset to clients.”

Mr. Bishop’s expertise extends to strategic, regulatory, financial, and transactional matters for electric and natural gas utilities, natural gas pipelines and storage developers, and independent energy project developers. He has worked on federal and state rate case proceedings, valuations for ad valorem tax disputes, utility municipalization efforts, contractual disputes, purchase and sales transactions, regulatory strategy and policy matters, and competitive and market power concerns.

He has provided expert testimony and other filings in over 50 administrative and civil proceedings in the US and Canada, including before the Federal Energy Regulatory Commission (FERC), the Canada Energy Regulator (CER), and state and provincial regulatory agencies.

“I am thrilled to join the respected team of economists at The Brattle Group, especially during this pivotal time for the energy industry,” Mr. Bishop said. “I look forward to helping the firm continue its success and collaborating on regulatory economics and finance matters.”

Previously, Mr. Bishop was a Senior Vice President at an economic consultancy, and he also held positions at two management consultancies.

To learn more about Mr. Bishop, please see his full bio.

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Seven Experts Promoted to Principal at The Brattle Group https://www.brattle.com/insights-events/news/seven-experts-promoted-to-principal-at-the-brattle-group/ Thu, 10 Feb 2022 14:17:28 +0000 https://www.brattle.com/?p=45173 The Brattle Group is pleased to announce that seven experts were recently promoted to Principal: Hollie Mason, David McKnight, Albert Metz, Christine Polek, Akarsh Sheilendranath, Anul Thapa, and Mike Tolleth. “These talented individuals provide in-depth expertise to a vast array of clients on matters related to financial services, energy, tax, and more,” shared Brattle President […]

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The Brattle Group is pleased to announce that seven experts were recently promoted to Principal: Hollie Mason, David McKnight, Albert Metz, Christine Polek, Akarsh Sheilendranath, Anul Thapa, and Mike Tolleth.

“These talented individuals provide in-depth expertise to a vast array of clients on matters related to financial services, energy, tax, and more,” shared Brattle President & Principal David Sunding. “In addition, they have made exemplary contributions to mentoring and developing their colleagues, and truly demonstrate the exceptional leadership pipeline we are fortunate to have at the firm.”

Our new Principals:

  • Hollie Mason | Practice Leader: Broker-Dealers & Financial Services | Chicago
    An attorney with more than 15 years of experience in the financial industry, Ms. Mason provides expert testimony and consulting services concerning securities litigation and enforcement matters. She has deep knowledge of Financial Industry Regulatory Authority (FINRA) and Securities & Exchange Commission (SEC) rules.
  • David McKnight | New York
    Mr. McKnight has over 20 years of experience providing expert testimony and consulting services in matters pertaining to mass torts, securities, finance, valuation, and bankruptcy. In mass tort matters, he has worked with liability forecasts, insurance coverage, and discounted cash flows.
  • Albert Metz | New York
    Dr. Metz is a securities and finance expert with deep experience in credit analysis, financial modeling, asset pricing, market efficiency, and event studies. He has consulted on asset pricing, antitrust, mergers and acquisitions, market manipulation, collusion, fixed income securities, and various debt derivatives.
  • Christine Polek | Boston
    Ms. Polek serves as a consulting and testifying expert in complex litigation requiring the application of economic, financial, and statistical analysis to legal and regulatory issues – with a focus on valuation, tax controversy, and labor and employment.
  • Akarsh Sheilendranath | Boston
    Mr. Sheilendranath is an energy economist with a unique blend of expertise in wholesale electricity markets, electric transmission, and regulatory corporate finance. He specializes in transmission policy, utility investment strategy and planning, large-scale renewable integration, and cost-benefit assessments.
  • Anul Thapa | Boston
    Mr. Thapa has over 12 years of experience applying economic and finance principles in complex oil and gas-related litigation, arbitration, and regulatory proceedings. His experience in commercial disputes includes damages estimation, valuation, and pricing related to energy assets and contracts.
  • Mike Tolleth | New York
    Mr. Tolleth specializes in the economic analysis of energy markets, with expertise in financial modeling and valuation of energy assets, contracts, and businesses. He supports clients in litigation and arbitration matters and provides expert testimony related to cost of service, rate design, cost of capital, regulatory policy, long-run marginal cost pricing, and market power.

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American Finance Association Announces 2021 Recipients of The Brattle Group Prize https://www.brattle.com/insights-events/news/american-finance-association-announces-2021-recipients-of-the-brattle-group-prize/ Tue, 18 Jan 2022 14:17:17 +0000 https://www.brattle.com/?p=45017 Each year, the associate editors of The Journal of Finance select three winners to receive the Brattle Group Prize for outstanding papers in corporate finance. The Brattle Group supports this yearly award in an effort to recognize the importance of excellence in providing groundbreaking analysis and debate on compelling issues facing the corporate finance community. First Prize, $25,000: Peter […]

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Each year, the associate editors of The Journal of Finance select three winners to receive the Brattle Group Prize for outstanding papers in corporate finance. The Brattle Group supports this yearly award in an effort to recognize the importance of excellence in providing groundbreaking analysis and debate on compelling issues facing the corporate finance community.

First Prize, $25,000: Peter M. DeMarzo and Zhiguo He
Leverage Dynamics without Commitment
The Journal of Finance,
December 2020

Distinguished Paper, $10,000: Itamar Drechsler, Alexi Savov, and Philipp Schnabl
Banking on Deposits: Maturity Transformation without Interest Rate Risk
The Journal of Finance,
February 2021

Distinguished Paper, $10,000: Pat Akey and Ian Appel
The Limits of Limited Liability: Evidence from Industrial Pollution
The Journal of Finance,
February 2021

The Brattle Group has funded this yearly award for more than 20 years. These prizes are presented at the AFA’s annual meeting, and this year’s awards were announced at the virtual 2022 ASSA/American Finance Association’s (AFA) Annual Meeting on January 7–9. All papers published in the prior year’s issues of The Journal of Finance are eligible. We congratulate the winners on their achievement!

View a Complete List of Past Winners

More about the AFA

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Brattle Principal Michael Cragg Quoted in Boston Globe Article on Offshore Tax Legislation https://www.brattle.com/insights-events/news/brattle-principal-michael-cragg-quoted-in-boston-globe-article-on-offshore-tax-legislation/ https://www.brattle.com/insights-events/news/brattle-principal-michael-cragg-quoted-in-boston-globe-article-on-offshore-tax-legislation/#respond Tue, 07 Dec 2021 21:46:09 +0000 https://www.brattle.com/?p=29573 Brattle principal Michael Cragg was quoted in a July 27, 2011 Boston Globe article, in which he discusses the possible consequences of a bill designed to stop foreign insurance companies from shifting premiums paid by their U.S. customers to offshore tax havens. The article, “Even with debt, US not closing offshore loophole,” discusses Massachusetts Congressman […]

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Brattle principal Michael Cragg was quoted in a July 27, 2011 Boston Globe article, in which he discusses the possible consequences of a bill designed to stop foreign insurance companies from shifting premiums paid by their U.S. customers to offshore tax havens. The article, “Even with debt, US not closing offshore loophole,” discusses Massachusetts Congressman Richard Neal’s fight to stop foreign insurances companies from moving premiums paid by U.S. customers to offshore, tax-free zones.

Dr. Cragg recently authored a report which demonstrates that U.S. homeowners and business operators, especially those residing in coastal areas such as New England, would see rate increases of more than two percent if Mr. Neal’s legislation passed. Offshore reinsurers would no longer conduct business in the U.S., thus limiting supply and driving up cost of insurance, as well as eliminating any taxes that would be collected.

“That is going to essentially tax away all of the profit that would allow them to do business in the United States,” Dr. Cragg explains in the article.

To read the article in its entirety, please visit the Boston Globe website.

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Brattle Principal Michael Cragg’s Testimony Contributes to Favorable Ruling for U.S. Department of Justice in Principal Life Insurance Company v. United States of America https://www.brattle.com/insights-events/news/brattle-principal-michael-craggs-testimony-contributes-to-favorable-ruling-for-u-s-department-of-justice-in-principal-life-insurance-company-v-united-states-of-america/ https://www.brattle.com/insights-events/news/brattle-principal-michael-craggs-testimony-contributes-to-favorable-ruling-for-u-s-department-of-justice-in-principal-life-insurance-company-v-united-states-of-america/#respond Tue, 07 Dec 2021 21:41:31 +0000 https://www.brattle.com/?p=29432 Experts at The Brattle Group assisted attorneys for the U.S. Department of Justice to obtain a favorable ruling in recent litigation involving Principal Life Insurance Company. In 2000, Principal Life Insurance Company entered into a complex structured finance transaction with two large French commercial banks. The American life insurance company contributed $300 million into subsidiaries […]

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Experts at The Brattle Group assisted attorneys for the U.S. Department of Justice to obtain a favorable ruling in recent litigation involving Principal Life Insurance Company. In 2000, Principal Life Insurance Company entered into a complex structured finance transaction with two large French commercial banks. The American life insurance company contributed $300 million into subsidiaries of the French banks, and claimed foreign tax credits from a $1.2 billion portfolio of assets held before the transaction by the French banks. To provide the incentive for the French entities to enter the transaction, the $300 million was structured as a below market loan. A team of Brattle experts reviewed the documents and financial models behind the transaction and provided testimony analyzing the substantive economic effects of the transaction. During a two-week trial in Iowa, Brattle principal Dr. Michael Cragg provided testimony that the transaction was only structured to extract foreign tax credits from the U.S. Treasury, and that no risk or ownership of the underlying assets had been transferred to Principal Life Insurance. In October 2011, the Court ruled in favor of the United States, awarding the government back taxes, interest, penalties, and court costs. In his opinion, Judge Jarvey extracted several exhibits directly from Dr. Cragg’s testimony, and specifically adopted Brattle’s explanations and analysis in rendering his decision for the government. Dr. Cragg was supported by Brattle principal Lynda Borucki and senior associate Evan Cohen.

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