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.

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.

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SPONSORED REPORT

Tax reform changes are now in effect

With all the recent tax law changes, this year it’s more important than ever to make sure your clients’ tax situations are squared away before year end. This report provides necessary guidance to ensure 2019 starts without a hitch.

DEDUCTIONS

Understanding the new Sec. 199A business income deduction

The new deduction allows certain business owners to keep pace with the significant corporate tax cut provided by the Tax Cuts and Jobs Act.