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Alston & Bird
Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles.
Mayer Brown
On August 13, 2021, the IRS released a Chief Counsel Advice ("CCA") (CCA 202132009) addressing the tax treatment of intercompany reimbursements of the Branded Prescription Drug ("BPD") fee...
Ruchelman PLLC
Two transfer pricing cases, in Australia and in Canada, address arm's length transfer pricing methodology for mined minerals during a period of steep increases in spot prices. In each case
Blue J Legal
Tax practitioners frequently struggle when providing advice on some cases in areas of tax law that have limited statutory guidance and a sizable body of case law.
Mayer Brown
On September 9, 2021, the Treasury Department and the Internal Revenue Service ("IRS") issued its Priority Guidance Plan for 2021-2022.
Mayer Brown
On September 7, 2021, the US Treasury published final regulations1 that, among other things, prohibit Internal Revenue Service (IRS) contractors from questioning witnesses during summons interviews.
Mayer Brown
A recent Tax Notes article analyzes the "standard of review" that the Tax Court will apply to the IRS's transfer pricing adjustments. In transfer pricing cases, the Tax Court determines whether the IRS has abused its ...
Mayer Brown
On April 15, 2020, OECD released the report titled "Tax and Fiscal Policy in Response to the Coronavirus Crisis: Strengthening Confidence and Resilience" (the "COVID-19 Response").
Caplin & Drysdale
An IRS Office of Chief Counsel memorandum released July 16, 2021 provides a roadmap for IRS transfer pricing examinations involving cost sharing agreements that omit stock-based compensation from the pool of shared IDCs.
Mayer Brown
After Altera's victory in Tax Court in 2015,[1] many companies with cost sharing arrangements ("CSA") ceased sharing stock-based compensation ("SBC") costs.
Miller & Chevalier Chartered
Last week Senate Democrats, led by Senate Majority Leader Charles Schumer (D-NY), announced an agreement on a $3.5 trillion package that includes President Biden's spending priorities...
Mayer Brown
For over a decade, countries have been looking for ways to tax the digital economy. On July 1, 130 countries announced an agreement that would provide a new taxing right to enable a country to tax a portion of ...
Mayer Brown
As discussed in prior blog posts, Amount A will apply as an overlay to the existing profit allocation rules. As the profit of an MNE group is already allocated under the existing profit allocation rules...
Mayer Brown
In the dawn years of transfer pricing, when the bulk of international trade focused on tangible goods, relatively little attention was devoted to the analysis of transactions involving services.
Mayer Brown
Assume the Internal Revenue Service ("IRS") is auditing your company's transfer pricing.
Mayer Brown
In February 2021, the Organisation for Economic Co-operation and Development issued a handbook linked with the official roll-out of its International Compliance Assurance Programme.
Mayer Brown
In 2021, the COVID-19 pandemic continues to change how US taxpayers, the Internal Revenue Service (IRS), and courts approach tax controversies.
Mayer Brown
The headline news about the U.S. Tax Court's decision on the value of Michael Jackson's estate might have been a shock to some – or, perhaps, to many.
Worldwide
Mayer Brown
On October 8, 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) announced that 136 countries have agreed on a two-pillar framework that would dramatically alter the taxation of multinational enterprises (MNEs).
Alston & Bird
Although the negotiation process has slowed due the Covid-19 pandemic, demand for bilateral advance pricing agreements (APAs) between India and the US continues to ...
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