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Caplin & Drysdale
More hiring and putting the Covid-19 pandemic in the rear-view mirror are paying off for the IRS unit that handles companies' advance tax deals on intercompany transactions.
Alvarez & Marsal
In this article, we explore the landmark decision in Pepsi Inc v Commissioner of Taxation [2023] FCA 1490 and its implications for the characterisation of royalties for multinational enterprises.
Fenwick
The International Compliance Assurance Program is a voluntary program that helps companies assess international tax risks to quickly achieve greater tax certainty across multiple jurisdictions...
Alvarez & Marsal
A&M Tax Managing Director Dan Peters moderated a panel at TP Minds Americas on February 9th. Dan was joined by Sheetal Kumar of Baker Hughes, Tatyana Pashova...
Steptoe LLP
The Treasury Regulations do not expressly require taxpayers to consider implicit support when pricing intercompany loans.
Foley & Lardner
KPMG claims that its recently-obtained patent (U.S. Patent 11,720,842) enhances the historically tedious and error-prone transfer pricing process...
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.
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