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AICPA comments on proposed regs. on new transfer-pricing method

The comments are in response to Notice 2025-04, which announced plans for the simplified and streamlined approach as a new transfer-pricing method under Sec. 482 regulations for pricing of baseline marketing and distribution activities.

The funding rule under Sec. 4501(d) prop. regs.

Proposed regulations under Sec. 4501 apply the stock repurchase excise tax to a parent corporation that “funds by any means” a stock repurchase. But the proposed regulations lack clarity on the phrase’s interpretation.

A closer look at the costs of borrowing

Comparison of the accounting and tax treatment of interest expense may reveal crucial differences and lead to best practices for managing it.

The research credit: Business-component requirement

The Fifth Circuit’s decision in Grigsby, 86 F.4th 602 (5th Cir. 2023), emphasizes the need for taxpayers to clearly define business components when preparing and documenting their Sec. 41 credit.

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.

On DRD, the IRS seeks to have its cake and eat it too

The plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS Office of Chief Counsel held, contrary to the Service’s argument in a recent Tax Court case.