Amount B aims to standardize the remuneration of related party distributors that perform baseline marketing and distribution activities in a manner that is aligned with the arm's length principle.
Alston & Bird
Our International Tax Group analyzes the report on the IRS's Advance Pricing and Mutual Agreement Program and identifies important insights and trends for advance pricing agreements.
Caplin & Drysdale
The IRS does not require any taxpayer to develop a transfer pricing study.
Benchmarking—the process of screening, selecting, and analyzing comparable companies—is time consuming. Analysts can spend innumerable hours every year preparing transfer pricing documentation...
The 2020 Annual Report suggests that certain foreign competent authorities may have been more successful than others in overcoming COVID-19 disruptions.
As discussed in prior blog posts, Amount A is a proposed new taxing right over a share of residual profit of MNE groups that fall within its defined scope.
Consider the following hypothetical: Researchers at a US-parented drug company develop an artificial intelligence (or "AI") system that can identify new therapeutic targets with minimal human intervention.
The Mutual Agreement Procedure ("MAP") is a useful dispute resolution mechanism for multinational companies facing a transfer pricing...
Davies Ward Phillips & Vineberg
At the end of 2019, most U.S. tax practitioners expected that the most important U.S. tax developments in 2020 would cluster around two topics.
Caplin & Drysdale
The IRS has announced a new "Campaign." It will focus its attention on U.S. persons who have reduced their U.S. tax burden by claiming benefits under Puerto Rico Act 22.
Frost Brown Todd
Given the projected loss in tax revenue in 2020, and beyond, due to the COVID-19 pandemic, states are looking for ways to stop the bleeding, including through typical methods (e.g., raising tobacco, fuel and other excise taxes) ...
Torres Law, PLLC
As January 20, 2021 approaches and the advent of a new president and presidency emerges, what can we expect from a Biden administration and its Customs and Border Protection...
In February 2020, the Organization for Economic Cooperation and Development ("OECD") released Transfer Pricing Guidance on Financial Transactions ("Guidance").
Mr. Z is a U.S. resident under Code §7701(a)(30) for
purposes other than the foreign tax credit. He is a Green Card
Just in time for the holidays, the OECD has published detailed guidance about the impact of the COVID-19 pandemic on transfer pricing.
Taft Stettinius & Hollister
After a nearly decade-long dispute with the IRS, the U.S. Tax Court ordered Coca-Cola to pay $3.4 billion in additional taxes.
In transfer pricing analysis, the determination of the entity or entities within a multinational enterprise that are entitled to share in the returns derived by the group from exploiting...
The parties recently completed briefing on an IRS motion for partial summary judgment in Western Digital Corporation v. Commissioner.
On September 1, 2020, the IRS issued final regulations regarding the base erosion and anti-abuse tax codified in IRC §59A.
In February 2020, the Organization for Economic Cooperation and Development released Transfer Pricing Guidance on Financial Transactions.