Law360, New York (July 2, 2015, 5:08 PM EDT) -- In past years, many transfer pricing advisers have taken a wait-and-see approach to tax planning in light of the Organization for Economic Cooperation and Development's actions on intangibles. More recently, there have been numerous developments on a variety of tax fronts. Given the dynamic environment, it is more important than ever that a company prepare rigorous documentation in support of tax positions, especially if they may change in the coming months. In the face of change, it is better to be prepared with rigorous documentation than to rely on hope. In this article, I discuss why it is important to provide an appropriate degree of transparency and rigor in documentation studies, both in terms of the story a company tells about its arrangements and in the economic analysis....