ALJ Holds for Taxpayers in District of Columbia Transfer Pricing Cases

Overview


Stephen Kranz was attorney for oil companies that challenged the District of Columbia’s Office of Tax and Revenue (OTR) reliance on transfer pricing studies provided by audit firm Chainbridge Software LLC. The District of Columbia Office of Administrative Hearings cited the earlier Microsoft case argued by Mr. Kranz in disallowing the use of the studies, and he commented that “we have believed since the beginning of the Microsoft case that this method was fundamentally flawed.”