Case study 1
Pricing a commodity flow against published third-party terms
The group moved a commodity between related parties and had been benchmarking it on an operating margin, because that was what the previous file did. Public terms existed for the product. We tested whether a direct price comparison was workable, adjusted for the contract differences that could be identified and quantified those that could not, and concluded that the price comparison held. The engagement produced a documented method change, a comparison supported by published terms rather than by a database, and a written statement of why the margin approach had been set aside.
Case study 2
An internal comparable found in the client's own agreements
A licensor was preparing documentation for intercompany royalties and the search had gone straight to a database. Before accepting that, we asked what the company licensed to unrelated parties. It licensed the same technology outside the group, on terms that differed in scope but were otherwise close. We analysed the differences, made the adjustments that could be supported and documented those that could not. The engagement produced a file built on the client's own agreements, with the database search retained as a secondary check rather than as the primary evidence.
Case study 3
Benchmarking a distributor after the entrepreneur question was settled
The client's distribution company had been treated as the entrepreneur in an earlier file, which did not match what the people inside it actually did. We rebuilt the functional analysis first, asking who set prices, who carried inventory risk and who decided the marketing spend, and the tested party fell out of it. Benchmarking the distributor's operating margin against a screened set of comparables followed. The engagement produced a functional analysis the operating staff signed off, a search with its screening criteria recorded, and a range the client can test its results against each year.
Case study 4
Choosing the profit level indicator for a contract manufacturer
The manufacturer worked to the parent's specification, bought materials as directed and carried no market risk. The argument in the file was not about the method but about the indicator: whether to test the return on costs or the return on sales. We worked through what each one measures for a business of this kind, and which of them moves with matters outside the manufacturer's control. The engagement produced a documented choice of indicator, a comparable set screened to businesses with similar cost structures, and a note recording what would justify revisiting the choice.
Case study 5
Moving away from a price comparison as adjustments grew
A file had rested on a price comparison for years while the product and the contract terms drifted away from the comparable. Each year the bridging adjustments grew, until the result depended more on the adjustments than on the comparison itself. We said so in writing, tested a margin-based approach against the same facts, and documented the point at which reliability had shifted. The engagement produced a reasoned method change, the analysis supporting it, and an explanation of the history, so the change reads as judgement rather than as convenience.
Case study 6
Defending a method choice when the comparables were challenged
A reviewer objected to the comparable set and the client's instinct was to run a fresh search. We separated the objections first. Some went to the screening criteria, one went to the tested party, and none went to the method itself. Each was answered with its own material: the search strategy and rejection reasons for the first, the functional analysis for the second. The engagement produced a written response addressing the objections as they were put, a file reorganised so the reasoning could be followed, and no change to a method that had been correctly chosen.
Case study 7
A Home Kept in Canada After the Move Abroad
A dwelling left available is the tie the CRA weighs most heavily, and its treatment differs depending on whether it is rented at arm's length. The file settles the residence position first and the rental reporting second.
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Case study 8
Wintering in the US Long Enough to Become a US Filer
Days in the United States accumulate across three years, and enough of them make you a US resident for tax regardless of immigration status. The file counts the days properly and files the statement that keeps the position closer connection rather than residence.
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