Where the matter calls for it, we apply the multifactor framework articulated by the Ninth Circuit in Elliotts, Inc. v. Commissioner and adopted widely thereafter — weighing the employee’s role and qualifications, external and internal comparisons, the character and financial condition of the company, and any conflict of interest in how pay was set. Every engagement is documented to meet the standards governing expert reports and testimony, including the disclosure requirements of Federal Rule of Civil Procedure 26 where applicable.