May 9, 2023 12:16 PMOECD Transfer Pricing Guidance Bad Fit For EU, Critics Say
By Dylan Moroses
Recently published IRS internal guidance detailing how the agency will screen advance pricing agreement requests has some tax practitioners concerned that prospective certainty may be more difficult to secure.
By Matthew Guerry
The United Arab Emirates' Finance Ministry published a measure Thursday that outlines the transfer pricing documentation requirements for companies subject to the country's new corporate income tax.
By David Hansen
Mayer Brown has a new partner in its Washington, D.C., office who served as an international tax counsel with the Internal Revenue Service, the firm announced.
By Matthew Guerry
The Organization for Economic Cooperation and Development released mineral pricing guidance Wednesday that it drafted with another intergovernmental group to help developing nations tackle tax avoidance.
By Kevin Pinner
Double taxation is eliminated under model rules for the 15% global minimum tax plan known as Pillar Two, and declining to allow tax credits for the income-inclusion rule and undertaxed payment rule would be consistent with those rules, an IRS attorney said Tuesday.
By Kevin Pinner
Australia's government proposed levying a 15% global minimum tax starting next year in its budget on Tuesday, saying the package is expected to raise AU$370 million ($250 million) in additional revenue through 2027.
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.
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.
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.
May 3, 2023 06:59 PMEaton Says IRS Wrongly Lowered Dividend Income By $193M
May 1, 2023 06:49 PMBusiness Groups Urge Australia To Limit Global Tax Reporting
May 1, 2023 07:13 PMIRS To Screen APA Requests, Offer Preliminary Reviews
April 28, 2023 07:26 PMInt'l Transfer Pricing Guidelines Often Misapplied, Pros Say
April 27, 2023 10:32 PMCoca-Cola Can't Escape Brazil Income Allocations, IRS Says
April 27, 2023 05:21 PMPerrigo Says IRS Dropped $843M Tax Assessment
April 26, 2023 05:39 PMMultilateral APAs May Increase In Frequency, IRS Official Says
April 25, 2023 06:19 PMEU Tax Admins Need Better Cross-Border Data, Officials Say
April 24, 2023 04:50 PMIRS Lacks Power To Allocate Blocked Income, Coca-Cola Says
April 20, 2023 07:20 PMIndia's Top Court Says High Courts Can Probe Transfer Pricing
April 20, 2023 05:47 PMTax Policy Affects How Investment Is Made, Study Says
April 14, 2023 02:59 PMWeekly Internal Revenue Bulletin
April 12, 2023 05:36 PMUS, Global Min. Taxes May Shake Up Deal Planning, Pros Say
April 11, 2023 07:37 PMDeveloping Countries Still Skeptical Of Global Tax Plan's Value
April 3, 2023 02:03 PMIndia Signs Record Number Of APAs In Fiscal Year
March 31, 2023 05:08 PMMin. Tax Backstop Risks Destabilizing System, Experts Say
March 31, 2023 06:57 PMCoca-Cola's Brazilian Income Is Still Blocked, Tax Court Told
March 29, 2023 06:20 PMSome UN Experts See Value In Tool For Model Treaty Updates
March 29, 2023 04:22 PMPandemic Slowed APA Work In 2022, IRS Report Says