Paul Flignor

Representative Projects – Intercompany Pricing

• Successfully defended a Tier 1 automotive company with manufacturing operations in Puerto Rico under a Section 936 audit. Developed a novel analysis attributing entrepreneurial risk to activities described by the Internal Revenue Service as “routine” manufacturing.
• Reversed a proposed IRS adjustment of a wholly owned routine wholesale distributor under the comparables profits method by quantifying the impact of foreign exchange and market sales risk.
• Integrated the intellectual property of a European acquisition into a US-based technology company. Structured the sale transaction of the intellectual property, and established joint development agreements, intercompany pricing arrangements and financial policies.
• For a global information technology and services company, developed a global cost-sharing and cross-licensing arrangement that integrated several acquisitions. Developed an intellectual property management structure and global intercompany pricing policies.
• For several emerging technology companies, established global intellectual property management policies, including cost sharing and global licensing arrangements. Integrated business, tax and statutory needs into a multi-disciplinary effort.
• Developed a European principal structure for an international chemical company. Designed the business case for management reorganization, and developed the intangible asset migration strategy cost sharing agreement, commissionaire and toll manufacturing arrangement. Designed administrative procedures to manage financial policies efficiently.

Representative Projects – Transaction Support

• Performed buy-side due diligence for a targeted optical products manufacturer. Identified off-book liability related to an overvalued intellectual property. This work led to a 15 percent reduction in purchase price.
• Led a team valuing the legal entities of a recently acquired electronics manufacturer for allocation of goodwill under FASB 141 and Section 338. Determined the value of operations in over 30 countries, incorporating differences in business functions, product lines, financial risks and macroeconomic conditions.
• Performed due diligence review of a consumer health care acquisition target with an offshore principal structure. Identified potential weaknesses in the underlying intellectual property valuation and intercompany pricing policies and estimated off-book tax liability.

Representative Projects - Intellectual Property Valuation and Management

• For a high-end fragrance line, valued a buyout covenant of a renegotiated licensing agreement for packaging, trade dress and related intellectual property.
• Valued and provided negotiation strategy support for the license and sale of an uncommercialized business method patent.
• For a major industrial products company, led the valuation component of a post-merger integration engagement. Valued business entities and associated intellectual property for the integration of 5 recently acquired companies.