Procter & Gamble
Procter & Gamble et. al. v. The United States of America
Robert Noah, an expert witness for the United States, was asked to address the purported non-tax business purpose of a series of transactions involving an inter-company transfer payment, pre-payment for goods, and related impacts on risk management and, in particular, foreign currency hedging. Dr. Noah’s analysis addressed valuation, hedging efficiency, hedging costs, and business purpose for transactions related to significant claimed tax reduction. The Court ruled in favor of the United States in summary judgment.