As the OECD member states plan to review the CbC framework in 2020, this discussion highlights several common issues large U.S. MNEs may face.
This item discusses punitive tarriffs.
Effectively navigating transfer-pricing regulations may be less about avoiding taxes and more about making smart decisions.
Imposition of a base-erosion and anti-avoidance tax adds fresh complexity to the calculation of transfer-pricing tax and accounting results.
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.
The consideration of a border tax adjustment on goods imported may persuade multinational businesses to reevaluate their intercompany supply chain, having transfer-pricing implications.
The Tax Court held that Amazon.com had properly valued transfers of intangibles under a cost-sharing arrangement with its Luxembourg subsidiary.
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.
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.
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.