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Paul Flignor

Paul Flignor

Principal Economist
About

Paul Flignor concentrates his practice in intercompany pricing and intellectual property valuation.

He has more than 15 years of professional experience in resolving pricing and valuation issues in the areas of international tax planning, controversy resolution, transaction support, licensing and financial economics. He is noted particularly for integrating business strategy and financial economics to solve complex valuation problems of leading companies.

Paul has worked extensively in the automotive, information services, software, consumer products and electronics industries. Over the years, he has successfully run transfer pricing and valuation projects for a variety of purposes, including:

  • Intercompany pricing, including audit defense, Advanced Pricing Agreements, cost sharing and intangible migration, and global documentation;
  • Business valuation for both tax and financial reporting purposes, including purchase price allocation;
  • Transaction support, including due diligence analysis and pre- and post merger integration planning;
  • Intellectual property valuation and management.

He is an adjunct professor at Northwestern University, where he teaches courses in corporate value chain management.

Paul Flignor is not a lawyer.

Areas of FocusTax

EXPERIENCE

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.
Education
  • M.B.A., Finance, The University of Chicago 1990
  • A.B., Economics, The University of Chicago

Prior Experience

Before coming to DLA Piper, Paul was a partner with multinational professional services firm's valuation and transfer pricing practice, where he led the transfer pricing automotive industry efforts. For several years, he also was a principal in the strategy and economic consulting practice at A. T. Kearney, a leading international management consulting firm.

Memberships And Affiliations

  • American Society of Appraisers, Licensing Executive Society

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