Deloris Wright
DELORIS R. WRIGHT, Ph.D.
President
| Phone: (720) 407-7306 Cell: (303) 304-6722 dwright@wrighteconomics.com |
602 Park Point Drive Suite 105 Golden, CO 80401 |
Dr. Wright, President of Wright Economics Inc, specializes in economic studies that deal with worldwide transfer pricing issues. She is also experienced in the valuation of intangible assets and the application of statistical methods and econometric analysis. She has dealt with virtually every type of transfer pricing issue, from pricing of tangible and intangible property to determination of arm’s length service fees. She assists clients with planning as well as audit issues and has experience dealing with many of the world’s tax authorities. Her transfer pricing experience encompasses a broad range of industries, including computer hardware and software, food products, pharmaceuticals, manufacturing, electronics, and the services industries.
Prior to joining the firm, Dr. Wright led the transfer pricing practices of Charles River Associates, Analysis Group, Inc., and Coopers & Lybrand. She spent four years as an economist with the Internal Revenue Service, where she gained substantial knowledge and experience related to intercompany pricing audits. Dr. Wright was also a professor of economics for six years.
Dr. Wright has been an invited speaker at numerous seminars including those sponsored by the IBFD, the Tax Executives Institute and the Financial Executives Institute. She has been published widely in leading transfer pricing journals, including the International Transfer Pricing Journal and the Transfer Pricing Report, and various other international tax journals. She is the author of CCH’s U.S. Transfer Pricing Guide and serves on the editorial board of the International Transfer Pricing Journal. In addition to her publishing activities, Dr. Wright was named the chair of the IBFD’s transfer pricing advisory board.
Dr. Wright has performed significant work for numerous clients, including the following:
- A major computer manufacturing company – pricing study involving sale of components to the United States from Singapore and Irish subsidiaries.
- A major software company – pricing study involving sale of products to a US company by its Puerto Rican subsidiary.
- A major US corporation – pricing study involving buying agent’s commission paid to Far East buying agent.
- A major US corporation – pricing study for products produced by its Irish subsidiary.
- A major international software company – royalty study for its Irish subsidiary.
- A major US manufacturing and retail organization – pricing study involving a UK parent and its related corporations in Europe.
- A major food products company in the United States – pricing study involving sales of tuna fish from its Puerto Rican subsidiary.
- A major international computer company – worldwide pricing study involving related companies in the United States, Japan, Hong Kong, Bahamas, and many European countries.
- A major brewing company – pricing study for beer brewed outside of the United States and sold to a related company in the United States.
- A major manufacturer of computer peripherals – pricing study for computer peripherals manufactured by a Puerto Rican subsidiary and sold to the US parent.
- Two major Japanese electronics corporations – pricing study between the Japanese parent and its US subsidiary.
- A major UK company – pricing study involving the United States, the UK parent, and Panamanian and other affiliates located in other parts of the world.
- A major international pharmaceutical company – pricing study involving a Puerto Rican subsidiary.
- A major tobacco company – pricing study involving US, Dominican Republic, and Puerto Rican operations.
- A glass manufacturing company – pricing study involving European and US affiliates.
EDUCATION
TESTIFYING EXPERIENCE
- Alberta Printed Circuits Ltd v. Her Majesty the Queen, on behalf of the Crown, Tax Court of Canada, Court File No: 2008-714 (IT)G, February 2011.
- General Electric Capital Canada Inc v. Her Majesty the Queen, On behalf of the Crown, Tax Court of Canada, Court File No.: 2006-1386 (IT)G and 2006-1385 (IT)G, June 2009
- Roche Products Pty Limited v. Commissioner of Taxation, On behalf of the Commissioner, Administrative Appeals Tribunal, Taxation Appeals Division, Sydney Registry. February 2008
- In the Matter of the Petition of Kellwood Company vs. New York State Department of Taxation and Finance, On behalf of Kellwood Company, DTA #820915, March 2007
- Joe Comes; et al. v. Microsoft Corp. , State of Iowa District Court for Polk County Rebuttal expert report (2006) and deposition testimony (2006) in an antitrust case involving an analysis of the economics of the computer software industry and the resulting implications for market structure and profitability.
- IN RE WORLDCOM, INC., et al., United States Bankruptcy Court, Southern District of New York, Chapter 11. On behalf of Ad hoc Trade Claims, Case No. 02-13533 (AJG), September 2003
- Ford Motor Company of Canada, Limited and Ontario Municipal Employees Retirement Board, Et Al., Ontario Superior Court of Justice (Commercial List), On behalf of Ford Motor Company, Cause No. 95-CO-93270, May, 2002
SELECTED PUBLICATIONS
“Proposed Changes to US Transfer Pricing Law,” co-authored, International Transfer Pricing Journal, Volume 17, Number 6, 2010.
“Pricing of a Guarantee Fee in a Related-Party Context,” International Transfer Pricing Journal, Volume 17 – Number 4, 2010 .
“Xilinx: The Saga Continues,” International Transfer Pricing Journal, Volume 17 - Number 3, 2010.
“Withdrawal of Court of Appeals Decision in Xilinx,” International Transfer Pricing Journal, Volume 17 - Number 2, 2010.
“The Tax Court Decision in Veritas: A Comment,” co-authored, International Transfer Pricing Journal, Volume 17 – Number 2, 2010.
“Transfer Pricing in Recession,” co-authored, International Transfer Pricing Journal, Volume 16 – Number 5, 2009.
“R&D Cost Sharing: The Xilinx Appeal,” co-authored, International Transfer Pricing Journal, Volume 16 – Number 5, 2009.
“US Temporary Cost Sharing Regulations – A Comment,” co-authored, International Transfer Pricing Journal, Volume 16 – Number 3, 2009.
“Comments on the OECD Discussion Draft on Transfer Pricing Aspects of Business Restructurings,” co-authored, International Transfer Pricing Journal, Volume 16 Number 2, 2009.
“Transfer Pricing for Transactions Involving Low-Tax Countries,” International Transfer Pricing Journal, Volume 15 Number 1, 2008.
“Update on Sec. 482 Services Temporary Regulations” co-authored, International Transfer Pricing Journal, May/June 2007.
“Sec. 482 Services Regulations: Implications for Multinationals” co-authored, International Transfer Pricing Journal, November/December 2006.
“An Assessment of APA Fee Increase” co-authored, International Transfer Pricing Journal, May/June 2006.
“Proposed US Cost Sharing Regulations: A Departure from Arm’s Length?” co-authored, International Transfer Pricing Journal, January/February 2006.
“IRS APA Initiatives” co-authored, International Transfer Pricing Journal, September/October 2005.
“Comment on PATA Guidance for Bilateral APAs” co-authored, International Transfer Pricing Journal, January/February 2005.
“Location Savings – A US Perspective,” Co-author, International Transfer Pricing Journal, July/August 2004.
“United States: Cost Sharing, Services and Intangibles: Recent Changes in Transfer Pricing Regulations” International Transfer Pricing Journal, Volume 11, Number 1, 2004.
“Transfer Pricing in the UK – A Practical Update” Bureau of National Affairs Transfer Price Report, October 1, 2003.
“Practical Implications of the PATA Documentation Package,” International Transfer Pricing Journal, May/June 2003.
“Transfer Pricing 2001: The Year in Review” U.S. Transfer Pricing Guide: Practice and Policy. CCH.
“Certain Issues in the Use of Profit-Based Methods,” George Mason University Law Review, Summer 2002.
“Stock Option Expense and Cost Sharing: A Comment,” Transfer Pricing Report, October 2, 2002.
“United States: Transfer Pricing When Losses Arise,” International Transfer Pricing Journal, September/October 2002.
“Announcement and Report Concerning Advance Pricing Agreements: A Comment,” International Transfer Pricing Journal, July/August 2001.
“Transfer Pricing in the United States: Recent Events and Expectations for the Future,” Bulletin for International Fiscal Documentation” Special Issue, Volume 55, Number 9/10, 2001.
“Transfer Pricing 2000: The Year in Review” U.S. Transfer Pricing Guide: Practice and Policy. CCH.
“Practical Application of Transactional Profit Methods” International Transfer Pricing Journal, 7, No. 5. September/October 2000.
“Secrecy of Advance Pricing Agreements in the United States” International Transfer Pricing Journal 7, No. 2. March/April 2000.
“Report on the Application and Administration of Section 482: A Commentary.” International Transfer Pricing Journal 6, No. 5 (September/October 1999).
“The DHL Case: What Lessons Can Be Learned?” Co-author. International Transfer Pricing Journal 6, No. 3 (May/June 1999).
“Extraordinary Market Conditions, Chapter 11A” and “Economic Issues in Market Share Strategies, Chapter 19B.” Transfer Pricing Handbook, Second Edition, 1999 Supplement.
“Cost Plus Method: A United States Perspective.” International Transfer Pricing Journal 6, No. 1 (January/February 1999).
“Transfer Pricing Documentation: A U.S. Perspective.” International Transfer Pricing Journal. 5, No. 3 (May/June 1998).
“Allocation of Functions and Risks within Multinational Enterprises.” Co-author. International Transfer Pricing Journal 4, No.6 (November/December 1997).
“The Arm’s Length Principle and Losses: United States Perspective.” International Transfer Pricing Journal, 4 (June 1997).
“Update to Cost Sharing Commentary.” CCH Update, 1997.
“OECD Chapter VI: Special Considerations for Intangible Property Issues and Analysis.” International Transfer Pricing Journal (January 1997).
“The Use of Regression Techniques in Transfer Price Analysis.” Co-author. International Bureau of Fiscal Documentation, 1996.
“Transfer Pricing Documentation Requirements – What Are Companies Doing To Comply?” Co-author. CCH update, 1996.
“Alternative Methods for Determining Arm’s-Length Intercompany Prices.” Co-author. Chapter 1 of Section V in Tax Treatment of Transfer Pricing. Amsterdam: International Bureau of Fiscal Documentation, 1995.
“TNMM – The OECD’s Response to CPM: Are They Really Different?” Co-author. European Taxation 1995.
“Economics and the New Transfer Pricing Regulations: Achieving Arm’s-Length Through the Invisible Hand.” Co-author. Tax Management Transfer Pricing Special Report, Vol. 4, No. 2, Report No. 17 (May 24, 1995).
“In the OECD and the United States, It’s the Arm’s-Length Principle that Matters: Comparison of New Transfer Pricing Regulations.” Co-author. International Transfer Pricing Journal 1, No. 4 (January 1995).
“Intangibles and Transfer Pricing.” International Transfer Pricing Journal 1 (April 1994): 5–17.
U.S. Transfer Pricing Guide: Practice and Policy. CCH, 1995.
Understanding the New US Transfer Pricing Rules. CCH, June 1993.
“Play-It-Safe Transfer Pricing.” Financial Executive (November/December 1992).
“Living with the Proposed §482 Regulations.” Co-author. Tax Management Inc. 33, No. 8 (April 20, 1992).
“Transfer Pricing: An Issue of Growing Importance.” Co-author. The Netherlands Chamber of Commerce Newsletter.
“Japanese Intercompany Pricing Legislation: Current Developments.” Co-author. Tax Planning International Review 19, No. 4 (April 1992).
“Section 482 White Paper: A Review of Third-Party License Agreements.” Co-author. The Tax Executive 41, No. 4 (July-August 1989): 353–358.
“The IRS §482 White Paper – Analysis and Commentary.” Co-author. Tax Management International Journal 18, No. 4 (April 14, 1989): 151–173.
“The Role of Functional Analysis in Intercompany Pricing.” Special Seminar on Issues in International Transfer Pricing. International Fiscal Association, Canadian Branch, Montreal, October 17, 1986.
“The Super Royalty: A Suggested Regulatory Approach.” Co-author. Tax Notes 36, No. 4 (July 27, 1987): 429–436.
“An Analysis of the Super-Royalty Provision of the Tax Reform Act of 1986.” Co-author. Tax Management International Journal (January 9, 1987): 17–21.
“A Critical Appraisal of the Tax Court’s Opinion in Eli Lilly.” Co-author. Tax Management International Journal 14, No. 9 (September 13, 1985).
“Post-Section 367(d) Strategies for Transferring Intangibles Overseas.” Co-author. Tax Management International Journal 14, No. 12 (December 13, 1985).
“Economics, Intangibles, and Section 482.” The International Tax Journal 10, No. 3 (March 1984).
