This article explores key recent developments that could impact proposed regulations as they become final.
The Tax Court held that the IRS had abused its discretion in reallocating income related to intercompany licenses for the intangible property to manufacture medical devices from a Puerto Rican company to its U.S. parent company.
The regulations would clarify the application of the arm’s-length standard when multiple Code sections apply.
Taxpayers will be required to consistently value transfer-pricing transactions for purposes of all Code sections under rules issued by the IRS.
Organisation for Economic Co-operation and Development guidance could offer cost savings to multinational companies, particularly small and compliant ones.
This article explains how a transfer-pricing adjustment triggers secondary financial consequences in a multinational group.
The IRS announced a reorganization of its advance pricing agreement (APA), mutual agreement, and competent authority programs into one new program.