TRM™ Recent & Past Cases/Matters for Clients
South Africa – USD$400m – transfer pricing royalty charges – MNE operations in Africa, Asia, Middle-East and Europe
South Africa – USD$80m – transfer pricing royalty charges/legal & economic ownership
Uganda – USD$54m – transfer pricing management fees & capital v revenue deductions
South Africa – USD$60m – customs/excise – liquor industry classification dispute
Malawi – USD$43m – transfer pricing
Rwanda – USD$ approx. 12m – transfer pricing & VAT
Zambia – USD$55m – exit tax/lien
Zambia – USD$approx. 10m – transfer pricing dispute in the manufacturing sector
Zimbabwe – USD$20m – transfer pricing agricultural industry
Romania – tax risk management process for MNE based world-wide
Hungary – tax risk management process for MNE based world-wide
US – USD$30m – advice on no tax residency in US to eliminate exit tax
US – advice on no tax residency in US for CEO of UAE royal family owned operation
US – advice & representation on late FBAR filings and IRS Offshore Voluntary Disclosure Program
US – advice to US tax practitioners as specialist on OIC, EITC, late FBAR/PFIC/Form 5471/Form 8840 filings
US – tax court petitions – failure to file/arrear taxes – Canadian doctor & citizen
US – advice on tax court petition – Schedule C landscaping business deductions
US/Africa – USD$100m – advice & structuring on foreign trust/corporation connection to US/Africa tax resident, receiving gift – ongoing
US/Africa – disinvestment from Africa operations – tax implications – controversy International Tax & State Responsibility relief
Nigeria – review MNE transfer pricing studies
S.Africa – USD10m – SARS back-dating revised assessment – on appeal to tax court
S.Africa – USD$30m – VAT apportionment of input tax credits
S.Africa – search & seizure warrant & tax audit/investigation
S.Africa – compile Africa-wide transfer pricing studies
Ireland/Africa – compile Africa-wide transfer pricing studies
Mauritius/Africa – compile Africa-wide transfer pricing studies
We pride ourselves in giving the highest degree of professional service to individuals, businesses, corporations, and MNEs (together with their usual advisors) on domestic and international planning, tax audit and tax litigation issues. Our successes are clear – and we DO NOT often go to court. We usually settle matters favourably for clients.