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Bennett Thrasher
Transfer pricing is a financial and tax accounting practice that determines the prices at which related entities within a multinational corporation transact with each other for goods, services, or...
Bennett Thrasher
The practice of transfer pricing involves assigning value to goods, services, and intangible property traded between legally distinct but related entities under a common...
Bennett Thrasher
On October 20, 2023, the Internal Revenue Service ("IRS") announced the launch of a three-pronged corporate tax compliance initiative as part of the Inflation Reduction Act of 2022...
Bennett Thrasher
Transfer pricing is a financial and tax accounting practice that determines the prices at which related entities within a corporate group transact with each other for goods, services, intangibles...
Kaufman Rossin
A transfer pricing study or analysis helps companies decide how to price transactions between related parties in different tax jurisdictions.
Steptoe LLP
As some officials had previewed in recent public statements, the IRS (through Chief Counsel) issued a memorandum...
Kaufman Rossin
A transfer pricing study or analysis helps companies decide how to price transactions between related parties in different tax jurisdictions.
Alvarez & Marsal
In today's global business landscape, multinational corporations face an increasingly complex task: managing their transfer pricing structure effectively.
Ruchelman PLLC
Except for the U.S., transfer pricing law frequently includes a provision that references the O.E.C.D. T.P. Guidelines as the guidance that must be used to interpret other provisions of relevant law.
Winston & Strawn LLP
Welcome to the October 2023 edition of the Winston & Strawn Monthly Tax Controversy newsletter. In this installment, we highlight both tricks and treats from the spooky month of October...
Caplin & Drysdale
Clark Armitage, David Rosenbloom, and Arjun Ghosh co-wrote the article "Is ICAP a Viable Alternative to APAs?" for IBFD International Transfer Pricing Journal 2023 in Volume 30, No. 5.
Winston & Strawn LLP
The Inflation Reduction Act of 2022 (IRA), passed into law on August 16, 2022, represented a shift in the world of U.S. federal tax enforcement. This shift—or as most might suggest...
Greenberg Traurig, LLP
Following their recent announcement regarding new partnership and global high wealth enforcement initiatives,1 the Internal Revenue Service (IRS) on Oct. 20...
Caplin & Drysdale
Clark Armitage offers insights in Indepth Feature: Global Tax for the October 2023 issue of Financier Worldwide Magazine.
Miller & Chevalier Chartered
Last month, the First Circuit Court of Appeals affirmed the Tax Court's decision in TBL Licensing LLC v. Commissioner holding that a reorganization resulting in the outbound transfer of intangible property (IP)...
Mayer Brown
In a recent case, Villa-Arce v. Commissioner, a whistleblower sent information to the IRS that he believed showed that the company was using improper transfer pricing practices and taking unjustified deductions.
Mayer Brown
Last week, the IRS released a mysterious new audit "campaign" that may implicate – inadvertently or otherwise – transfer pricing practices.
Mayer Brown
Can the IRS sue a corporation because it believes the company underreported its taxes? You might think the answer is no — the IRS must first propose an adjustment...
Mayer Brown
On July 21, 2023, the Internal Revenue Service ("IRS") released Notice 2023-55 (the "Notice") providing temporary relief from the final foreign tax credit regulations issued in 2022 (the "2022 Final Regulations").
Loyens & Loeff
Loyens & Loeff New York regularly posts ‘Snippets' on a range of EU tax and legal topics. This is our latest Snippet on the upcoming public Country-by-Country reporting ("Public CbCR") obligations in Europe.
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