After a cross-border merger or acquisition, related affiliates often integrate and use the acquired intangibles, such as new products or innovative features. To help executives manage the resulting transfer pricing risk, this article examines the treatment of acquired intangibles in post-acquisition related-party transactions.
Cross Border Transactions
Global expansion of e-invoicing and digital reporting obligations for nonresidents
Countries are expanding e-invoicing and digital reporting obligations to nonresidents to increase value-added-tax compliance.
Strategic trade management in 2025: Navigating and mitigating tariffs
As tariffs continue to affect costs, U.S. importers can employ these strategies to minimize their duty exposure.
Disregarded-payment-loss rules: How multinationals should prepare
New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign disregarded entities.
Transfer pricing: The C-suite needs to be informed
CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous amounts at stake in tax disputes, financial reporting risk from uncertain tax positions, and customs valuations.
Advance pricing agreements: A realistic option for transfer pricing
In the long run, an agreement with a taxing authority is often a wiser choice than traditional compliance and dispute resolution methods.
Gain recognition agreements: US corporation’s transfer of a foreign corporation followed by the foreign corporation’s disposition of its assets
This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.
Secondary transfer-pricing adjustments
An inferred secondary transaction may be in the form of a deemed dividend, a deemed capital contribution, or a deemed loan.
Blockchain technology firms’ transfer-pricing issues
This article presents some of the transfer-pricing considerations that blockchain companies must address as they grow and expand across borders.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
