International Government Consulting
Robert Feinschreiber / Margaret Kent
United States – Assisted in the formulation of the DISC statute and regulations - 1970-1973 - DISC requirements under 26 USC section 992 and the regulations thereunder for the US Treasury Department, DISC assets requirements and gross receipts requirements under 26 USC section 993 and the regulations thereunder for the US Treasury Department, intercompany DISC transfer pricing under 26 USC section 994 and the regulations thereunder for the US Treasury Department, Robert Feinschreiber
Canada – Analyzed the Canadian capital cost allowance – function vs. material as principal components of the capital cost allowance; useful life analysis; comparison of the 26 USC section 167 provisions for the Canadian tax authorities 1971-1973 Robert Feinschreiber
United States – Participated in the tax inflation study under the Carter administration, 1977-1979 (using research from Chile, Brazil, Argentina, and Israel) as to depreciation and as to depreciation adjustments –Robert Feinschreiber
Brazil – Developed the research tax incentive in Brazil, including the double deduction for research, 1984-1986, suggested export incentives, developed the blacklist system – Robert Feinschreiber and Margaret Kent
Jamaica – Development of the tax exemption for FSCs with a view toward creating a FSC as venue, 1985-1987 Robert Feinschreiber and Margaret Kent
United Nations – Organized special economic zones in regional development, transnational economic cooperation in Eastern Europe and in Asia, 1992-1995 – Robert Feinschreiber and Margaret Kent
Russia – Planned for privatization and economic development, including private sector structures and accounting for these structures, in Moscow – Robert Feinschreiber and Margaret Kent
Latvia – Participated in the development of the Baltic Confederation between Latvia, Estonia, and Lithuania; meetings in Riga – Robert Feinschreiber and Margaret Kent
United States – Transfer pricing – support for transactional profit split method under the Bush administration. Under the direction of Treasury Secretary O’Neill and IRS Commissioner Rossotti, we met with and supported for the international transfer pricing economists in Washington D.C. and in Atlanta GA, 2001-2002. The OECD adopted the transactional profit split method in 2010 as the most appropriate transfer pricing method alternative in which a multinational enterprise deals in the integrated production of highly-specialized goods, makes unique and valuable products, deals in unique intangibles, provides or receives specialized services, or deals in the global trading of financial instruments – Robert Feinschreiber and Margaret Kent
United States – DISC audit guide 2008-2011 - Reviewed the 284 page U.S. DISC Audit Guide at the request of the IRS. The International Examiners are to administer the U.S. DISC Audit Guide, subject to IRS counsel approval – Robert Feinschreiber and Margaret Kent
Taiwan – Transfer pricing 2010 – applying the transactional profit split method in Taiwan and the region. The OECD adopted in 2010 the transactional profit split method as the most appropriate transfer pricing method alternative in which a multinational enterprise deals in the integrated production of highly-specialized goods, makes unique and valuable products, deals in unique intangibles, provides or receives specialized services, or deals in the global trading of financial instruments – Robert Feinschreiber and Margaret Kent
Malaysia – Transfer pricing 2011 – applying the transaction profit split method in Malaysia and the Asean market. The OECD adopted in 2010 the transactional profit split method as the most appropriate transfer pricing method alternative in which a multinational enterprise deals in the integrated production of highly-specialized goods, makes unique and valuable products, deals in unique intangibles, provides or receives specialized services, or deals in the global trading of financial instruments – Robert Feinschreiber and Margaret Kent
