Transfer Pricing

Top News

IRS Memo Reverses Agency Position On FDII Calculation

By Dylan Moroses

The Internal Revenue Service updated internal guidance for how the agency should account for deferred compensation expenses for purposes of calculating the deduction available for foreign-derived intangible income.

Too Soon To Act On Kraft's $7.8M Tax Bill, Canada Court Says

By David Hansen

The Canadian branch of Kraft Heinz should wait until it receives a CA$10 million ($7.8 million) tax bill before asking the court system to nullify the transaction that led to it, a British Columbia court ruled.

Attys Say Journalism Pushed Gov't Toward Tax Transparency

By Kevin Pinner

Journalists' work exposing the U.S., U.K. and European Union's shared failure to enforce extraordinary sanctions on Russia's economy and wealthy individuals motivated politicians worldwide to propose groundbreaking transparency measures, veteran government attorneys said at a conference Friday. 

UN Asks For Feedback On Transfer Pricing Committee Plan

By Matthew Guerry

The United Nations is taking comments on a working plan for a recently established subcommittee on transfer pricing.

Tax World's Racism Stymies Africa's Growth, Experts Say

By Kevin Pinner

Patriarchal, racist attitudes held by powerful players within the global financial system such as tax collectors, lawyers and accountants have stymied Africa's capacity to fund development and helped vindicate people robbing resources, experts said during a conference Wednesday.

Tax Secrecy, Biases Enable Wealth Inequality, Academics Say

By Kevin Pinner

Financial secrecy helps rich, powerful people from around the world, including Vladimir Putin, avoid and evade taxes, so countries should use the war in Ukraine to push for changes to end tax havens, European academics said during a conference Tuesday.


Expert Analysis

The Benefits Of Competent Authority In Int'l Tax Disputes

Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.

Taxpayer Considerations For La. Audit Program Participation

While the Louisiana Department of Revenue's recently announced transfer pricing managed audit program could resolve time-consuming, expensive audits for many taxpayers, companies nevertheless need to consider the attendant risks in participation, say Jaye Calhoun and William Kolarik at Kean Miller.

International Tax Reform's Implications For Transfer Pricing

As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

MORE COVERAGE

May 9, 2022 05:22 PM

Eaton Owes No Penalties On New Adjustments, 6th Circ. Told

May 6, 2022 03:03 PM

OECD To Bar Risk-Based Cos. From Digital Economy Tax Plan

May 5, 2022 05:54 PM

OECD, US Considering Pillar 1 Transition Relief, Officials Say

May 5, 2022 06:38 PM

Amazon Investors Told To Vote For Public Tax Reporting

May 2, 2022 07:31 PM

IRS Adequately Responded To Microsoft FOIA, Court Told

April 29, 2022 04:36 PM

UK's Tax Take From Transfer Pricing Up $880M Year-Over-Year

April 26, 2022 08:01 PM

Amount B Could Involve Routine Function List, Treasury Told

April 20, 2022 06:12 PM

Singapore Telecom Appeals Aussie Transfer Pricing Decision

April 12, 2022 02:06 PM

Mongolia Targeting Tax Avoidance By Mining Cos., OECD Says

April 6, 2022 09:19 PM

SEC Backs Amazon Holders On Global Tax Transparency Vote

April 5, 2022 04:55 PM

Vietnam, South Korea Consider Agreement On Double Tax

April 5, 2022 07:09 PM

Australia Developing International Tax Guidance, Advice

April 4, 2022 08:51 PM

Zero Prospect US Will Ratify Global Tax Deal, Atty Says

April 1, 2022 07:11 PM

India Reports 62 New Advance Pricing Agreements In 2021

March 31, 2022 08:40 PM

Contracts May Improve US Approach To Pillar 1, Officials Say

March 30, 2022 07:53 PM

Poland, Estonia To Veto EU Minimum Tax, Diplomats Say

March 30, 2022 07:44 PM

IRS Says Transfer Pricing Program Facing Increased Demand

March 23, 2022 06:05 PM

Key Ratifications A Must For Tax Deal, OECD Official Says

March 21, 2022 08:50 PM

Women Benefit From Progressive Tax Systems, Panelists Say

March 18, 2022 06:44 PM

Eaton Broke Transfer Pricing Agreements, 6th Circ. Told