Transfer Pricing

Top News

Weekly Internal Revenue Bulletin

By Theresa Schliep

The Internal Revenue Service released its weekly Internal Revenue Bulletin on Friday, highlighting a report on advance pricing agreements, guidance pushing back individual tax deadlines and an announcement allowing deductions for personal protective equipment.

APA Work Held Firm In 2020 Despite Virus, IRS Official Says

By Joseph Boris

Despite logistical hurdles raised by the coronavirus pandemic throughout most of 2020, the number of completed advance pricing agreements between the Internal Revenue Service and multinational companies ticked up from the previous year, a top IRS official said Tuesday.

Weekly Internal Revenue Bulletin

By Theresa Schliep

The Internal Revenue Service released its weekly Internal Revenue Bulletin on Friday, highlighting an announcement detailing the process for binding arbitration of double-tax disputes as covered in the U.S.-Japan treaty.

IRS Exploring TCJA's Impact On Transfer Pricing, Official Says

By Natalie Olivo

The Internal Revenue Service is looking at intersections between the 2017 federal tax overhaul and transfer pricing matters, including how some international measures could affect multinational corporations' advance pricing agreements, an agency official said Wednesday.

States Eye Advance Pricing Agreements At Revived MTC Group

By Maria Koklanaris

Helping multiple states craft agreements with companies that can decide ahead of time how states will deal with transfer pricing matters will be a possible focus for the Multistate Tax Commission's transfer pricing committee, which retooled Tuesday.

Virus May Prompt Reviews Of Low-Risk Biz, OECD Official Says

By Natalie Olivo

Multinational companies can argue that the coronavirus pandemic has caused some affiliates to bear more losses than usual, but doing so may require reassessing whether these entities were truly limited risk, an OECD official said Tuesday.


Expert Analysis

US Advance Pricing Agreements, Amid COVID And Before

Steptoe & Johnson's Matthew Frank, former director of the U.S. Advance Pricing Agreement Program, shares insights from an Internal Revenue Service report revealing an uptick in APA completions amid the pandemic, discusses trends over the program's 30-year history, and suggests ways taxpayers and the IRS could bolster program participation.

Coke, 3M Tax Cases May Not Settle Blocked Income Debate

Even if the challenged U.S. Department of the Treasury regulation on blocked income is struck down by the U.S. Tax Court in the pending Coca-Cola and 3M cases, the obligations of a taxpayer that had, but failed to avail itself of, alternative means to secure payment will remain an open question, say Matthew Frank and Amanda Varma at Steptoe & Johnson.

Applying OECD Guidance On COVID-19 Transfer Pricing

In light of the recently released Organization for Economic Cooperation and Development's guidance on the transfer pricing implications of the pandemic, taxpayers should be prepared to explain and defend their transfer pricing decisions for fiscal year 2020 for contemporaneous documentation and in future tax audits, say Susan Fickling andĀ TJ Michaelson at Duff & Phelps.

MORE COVERAGE

March 18, 2021 06:15 PM

Mining Co. Draws Mongolia's 1st Transfer Pricing Assessment

March 11, 2021 03:18 PM

Western Digital Wants $1.9B Tax Fraud Retaliation Suit Tossed

March 10, 2021 05:20 PM

Int'l Groups Back Virtual Approach For Tax Treaty Talks

March 6, 2021 01:21 PM

Treasury Mulling Source Issue For Cloud Regs, Official Says

March 5, 2021 07:16 PM

IRS Official Warns Against Act-Of-God Clauses In Int'l Cases

March 3, 2021 04:51 PM

Miner Rio Tinto To Contest $317M In Reassessed Aussie Taxes

February 26, 2021 05:32 PM

Lawmaker Pushes For International Tax Disclosure Rules

February 26, 2021 07:59 PM

US-Japan Agreement Spells Out Tax Treaty Arbitration Process

February 24, 2021 10:55 AM

Coke Hires Constitutional Expert For Transfer Pricing Case

February 23, 2021 03:57 PM

Majority Of Tax Pros Expect Enforcement Leap, EY Survey Says

February 19, 2021 02:50 PM

Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals

February 18, 2021 02:15 PM

OECD Says Pricing Book Adds Certainty For Cos., Tax Bodies

February 18, 2021 08:06 PM

Canada High Court Tosses Gov't Appeal In Mining Co. Tax Row

February 17, 2021 08:09 PM

Simpler Transfer Pricing Helps Developing Nations, Tax Pros Say

February 16, 2021 08:50 PM

OECD OKs 11 Of 13 Tax Zones' Int'l Dispute Resolution Plans

February 11, 2021 04:14 PM

Wider Int'l Transfer Pricing Program Sought, IRS Official Says

February 10, 2021 05:22 PM

Consider Mutual Agreement Procedures For Double Tax Relief

February 10, 2021 08:23 PM

Coke's Transfer Pricing Row With IRS Could Cost Up To $12B

January 29, 2021 12:11 PM

Winston & Strawn Adds 2 Partners From Eversheds

January 29, 2021 06:04 PM

Harter Reflects On US Role In OECD Digital Tax Project