John Warner, shareholder in the firm's Tax section, comments on businesses facing unprecedented losses that will require them to rework their intercompany tax planning in Bloomberg Tax's article "Virus Upends Tax Planning for Companies Facing Sudden Losses."
Companies might struggle to convince tax agencies that those losses are allocated at arm’s length, when they had previously based their transfer pricing models on allocating profits, said John P. Warner, a shareholder at Buchanan Ingersoll & Rooney PC in Washington.
“But now you have this extraordinary, once-in-a-century situation where those risks do eventuate,” Warner said.
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