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    Crude Oil and Natural Gas Prices are Random Walks

    Asset Intensity Adjustments in Transfer Pricing Lack Merit

    ITAT Transfer Pricing Decision on Use of the Resale Price Method

    Transfer Pricing and Financial Transactions in the UN Manual, OECD Guidelines and Brazil

    Pfizer’s Galactic Operating Profit Markup

    Working Capital Adjustments in Transfer Pricing

    Should Brazil Adopt the OECD Guidance on Intercompany Financing?

    Transfer Pricing Issues in Cloud Computing

    Multi-Year Analysis of Profit Indicators

    Return on Operating Assets Using Error Corrected Regression

    Practical Guide to Location Savings Analysis in Transfer Pricing

    Return on Assets (ROA) is Unreliable in Transfer Pricing

    Transfer Pricing and the Burden of Proof in Australia

    The Cumulative Advertising Effects on Sales

    The CPM/TNMM is a Multiplier Theory

    The Berry Ratio is Illegitimate Under the TNMM

    A Proposed Transfer Pricing Safe Harbor for US Retailers

    Danish Tax Court: Valuation of Intangibles and the DCF Model

    The Premature Death of the Comparable Uncontrolled Transaction (Price) Method

    Oligopoly Profit Markup

    Adecco Intercompany Royalty Litigation: CUP v. TNMM

    The Limited Risk Transfer Pricing Canard During a Pandemic

    The CAPM is Misapplied in Transfer Pricing

    Controversy Aside, IKEA on Solid Economic Footing in Royalty Dispute

    Creating Defensible Transfer Pricing Reports

    Translating Credit Ratings into Credit Spreads in Intercompany Financing

    Return on Assets When Assets are Exogenous

    The Standard Measure of Return on Assets is Biased

    Safe Harbors for U.S. Retailers

    Transfer Prices Based on EBITDA, not EBIT

    Transfer Pricing Methods Based on Operating Profits

    The “Return on Assets” Excludes Self-Developed Intangibles

    Effect of Text Redaction on Royalty Rates and Other Licensing Terms

    Royalty Rates for Licensed Intangibles and Minerals

    Another Look at Estimating Reliable Profit Indicators in Transfer Pricing

    Transfer Pricing Profit Indicators Using All Available Data

    Corporate Reorganizations in Transfer Pricing Need Economic Substance

    Applying Regression Analysis to Transfer Pricing's CUP Method

    The Profit Margin of US Retailers in Transfer Pricing

    The Profit Markup Model in Transfer Pricing

    Another Look at Using ROA in Transfer Pricing

    Return on Assets Using Adaptive Expectations in Transfer Pricing

    Alternative Functional Forms of Comparable Profits in Transfer Pricing

    Selecting Reliable Profit Indicators in Transfer Pricing

    Present Value of Intangibles in Transfer Pricing

    Profit Margin Using Koyck Transform in Transfer Pricing

    Return on Assets (ROA) is An Unreliable Profit Indicator in Transfer Pricing

    Intangible Assets in Transfer Pricing Are Not Hard-to-Value

    Transfer Pricing Memento

    Location Savings Adjustment to Profits in Transfer Pricing

    Profit Margin by Indirect Least Squares in Transfer Pricing

    Selecting the Appropriate “Net” profit indicator (NPI) in Transfer Pricing

    Coefficient of Variation of Return on Assets Used in Transfer Pricing

    Most Reliable Transfer Pricing Profit Indicator Based on Coefficient of Variation

    Using a distributed lag model to determine arm’s length profits in transfer pricing

    US and OECD Method for Computing arm’s Length Profit Margin in Transfer Pricing is Flawed

    Surplus Bargaining and the Effect of Contract Redaction on Royalties

    OECD Inventory Adjustment to Profits in Transfer Pricing is Spurious

    Adjusted COGS is a Proxy for Purchases in Transfer Pricing

    Hard-to-Value Intangibles Sans Mystere in Transfer Pricing

    Arm’s Length Profit Margin in Transfer Pricing

    Equilibrium Arm’s Length Profit Ratios in Transfer Pricing

    Enterprise Profits in Transfer Pricing

    Residual Profit Split in Transfer Pricing is an Avoidable Cul-de-Sac

    Forecasting Profit Margin Under CWI in Transfer Pricing

    The AR(1) Model of the Profit Margin in Transfer Pricing

    Determining Arm's Length Profit Margins Using the AR(1) Model in Transfer Pricing

    Operating Profit Margins Don't Obey the Normal Distribution

    Royalty Rates for Medical Devices

    Double Log Operating Profit Margin

    RoyaltyStat Keyword Search

    Profit Margin with Heterogeneous Variance

    Gross Profit Methods are Unreliable

    Profit Margin Using a Power Function

    Profit Margin of Corporate Innovators & Imitators

    IRS International Practice Units

    Selection of the PLI - Profit Margin

    Valuation of Intangibles: Pfizer Example

    Royalty Rates for Utility Patents

    Valuation of Intangibles: Measuring Excess Returns

    IRS Releases FY 2015 Data Book

    Valuation of Intangibles Based on Lagged Investments

    Economic Substance: Controlled Reorg Must Lead to Higher Profits

    US APMA Program, 2015 APA Statistics

    Valuation of Intangibles: Present Value Method

    Risk-Adjusted Asset Return

    Cross-Country Royalty Rates Converge

    OECD Released the Country-by-Country XML Schema

    Arm's Length Range - Most Reliable Measure

    Valuation of Intangibles From Initial Capital Stock

    Return on Assets - Correct Measure

    Valuation of Intangibles Based on the Perpetual Inventory Method (PIM)

    Royalty Rates in Patent Infringement

    Royalty Rates Are Stable Across Industries

    Intangibles Are Not Hard to Value

    Present Value of Intangibles May Not Be Realized

    Royalty Rates Are Great Ratios (Bis)

    Royalty Rates Are Great Ratios

    Comparable Royalty Rates

    Corporate Reorganizations Without Economic Substance

    Royalty Rates Large & Small

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