Transfer pricing

Amazon wins transfer-pricing case

The Tax Court held that the IRS’s determination, using a discounted-cashflow method, of the value of a CSA buy-in payment for Amazon.com’s transfer to a subsidiary of the right to use certain preexisting intangible assets in Europe was arbitrary, capricious, and unreasonable.

Taxpayer Wins Big in Transfer-Pricing Dispute

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.

Cost-Sharing Agreements and the Arm’s-Length Standard

The Xilinx case has created turmoil in the international tax community for quite some time, and there is no clear end in sight. Although the Ninth Circuit reversed its controversial decision, uncertainty surrounds the validity of Treasury’s new regulations explicitly requiring that cost sharing include stock options.

CPM: The World’s Transfer Pricing Method

The comparable profits method has emerged as the dominant transfer pricing method among multinational companies today due to its widespread acceptance by taxing authorities around the world, its administrative ease of use, and, often, opportunities for tax rate reduction.

Newsletter Articles

TAX REFORM

Traps for the unwary: Tax Cuts and Jobs Act changes

By now many of us are familiar with the various provisions of the law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97. Here is a list of changes together with (perhaps) unexpected nuances.

DEDUCTIONS

Qualified business income deduction regs. and other guidance issued

The package includes final regulations, guidance on how to calculate W-2 wages, a safe-harbor rule for rental real estate businesses, and new proposed rules on the treatment of previously suspended losses.