United States: Transfer Pricing

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

A First Sale Doctrine Checklist: Six Phases For Successful Tariff Reduction

Our recent blog post, The First Sale Doctrine: A Strategic Tool for Reducing Tariffs—But Only If You Do It Right, generated a lot of questions.

United States International

HS

Harris Sliwoski

Trump Signs Sweeping Tax Bill Into Law, With Major Implications For Corporate Clients Worldwide

President Trump has signed into law a comprehensive tax reform package that permanently extends several expiring provisions of the Tax Cuts and Jobs Act (TCJA) and enacts key tax measures central to his 2024 reelection...

United States Tax

CL

Carter Ledyard & Milburn

IRS Workforce Losses Pose Growing Risk To Businesses Amid Tariff-driven Tax Complexity

The Internal Revenue Service (IRS) is facing a steep workforce reduction that threatens its capacity to assist businesses just as many confront growing uncertainty around global trade...

United States Tax

WR

Wiley Rein

PER-10/PJ/2025, New Procedures For Tax Information Exchange

The Directorate General of Taxes (DGT) has issued PER-10/PJ/2025, an implementation regulation of Minister of Finance Regulation No. PMK 39/PMK.03/2017...

AM

Alvarez & Marsal

Section 899: Potential Tax Increases For Canadians Investing In The U.S.

United States Tax

GW

Gowling WLG

Navigating Tariffs And Income Taxes And Transfer Pricing

United States Tax

JD

Jones Day

Trade, Tariffs, And Tax Effects: Deal-Maker Considerations For Diligence And Structuring

United States International

R

Riveron

IRS Transfer Pricing Guidance: Adjustments Based On Actual Results

United States Tax

CD

Caplin & Drysdale

Three International Tax Cases Practitioners Must Watch In 2025

United States Tax

KR

Kaufman Rossin

Navigating BEAT And Transfer Pricing: Strategies To Minimize U.S. Tax Liability

United States Tax

MG

MGO CPA LLP

Hooray For New Math: Is It Really A Simplified Transfer Pricing Approach For 2025?

United States Tax

RP

Ruchelman PLLC

Prix De Transfert : La Détermination Du Taux D'intérêt De Référence Concernant Les Avances Intragroupe

European Union Tax

MB

Mayer Brown

OECD's Amount B: Simplified Transfer Pricing For Routine Marketing And Distribution Activities

GT

Greenberg Traurig, LLP

IRS Notices Adoption Of Amount B; Transfer Pricing Penalties Still In Play

United States Tax

CD

Caplin & Drysdale

Trump's Plan B For Tariffs

United States International

BG

Braumiller Law Group, PLLC

Avoid Costly Mistakes: Insights From Recent ERP Legal Battles (Video)

United States Technology

TS

Taft Stettinius & Hollister

[PODCAST] When Scammers Strike: How Mediation Can Help Resolve Consumer Fraud Claims

United States Litigation

J

JAMS

2025 Trade Policy Agenda Provides Rationale For Trump Tariff Actions

United States International

BG

Braumiller Law Group, PLLC

Trade Wars & Sanctions – The New Trade Order

United States International

BG

Braumiller Law Group, PLLC

Your U.S. Market Entry Pre-Arrival Tax Planning Checklist

Foreign direct investment (FDI) in the United States continues to grow, underscoring the country's appeal to global businesses.

United States Tax

MG

MGO CPA LLP

Contract Manufacturing: Considerations For Transfer Pricing In France

In the Bloomberg 2024 Transfer Pricing Forum, Senior Managing Director Emmanuel Llinares and Delsol Avocats Partner Julien Monsenego explain considerations for the transfer pricing of contract manufacturing

United States Tax

N

NERA

Thoughts On The Amount B Framework: Considerations For Contributions Within And Beyond The Baseline Scope

On 19 February 2024, the OECD/G20 Inclusive Framework on BEPS released its final report on Amount B of Pillar One, "Special Considerations for Baseline Distribution Activities."

United States Tax

N

NERA

IRS Issues Final Rules On Intangible Property Repatriations

With the allure of tax incentives for foreign derived intangible income and an increase in foreign audits scrutinizing transfer pricing, bringing intellectual property (IP) back to the United States...

United States Tax

MW

McDermott Will & Emery

Essential Guide To Transfer Pricing For Your Multinational Business

United States Tax

MG

MGO CPA LLP

Kilgour V Commissioner Of Taxation [2024] FCA 687: Regrettably On Arm's Length Terms

United States Tax

AM

Alvarez & Marsal

CFOs: Prepare Your Company For IRS Transfer Pricing Audits And Mitigate Risk

United States Tax

MG

MGO CPA LLP

The Aftermath Of Ya Global: Who Is A Partner?

United States Tax

RP

Ruchelman PLLC

Transfer Pricing: Insights For The Alternative Investment Industry

United States Tax

ML

Marcum

Tax Year 2024 Changes, Planning For Businesses To Consider

United States Tax

KR

Kaufman Rossin

So You Think You're In Control: When Do Transfer Pricing Rules Apply?

United States Tax

CD

Caplin & Drysdale

How Intercompany Agreements Can Mitigate Transfer Pricing Risk

United States Tax

MB

Mayer Brown

Proposed Dual Consolidated Loss Rules: More Traps For The Unwary

United States Tax

AM

Alvarez & Marsal

Supreme Court Opens The Doors To Federal Court Challenges To Treasury And IRS Regulations

United States Tax

SJ

Steptoe LLP

So You Think You're In Control: When Do Transfer Pricing Rules Apply?

Do the transfer pricing rules apply to your transaction? If you are asking that question because adjusting transfer prices could reduce your tax bill, the answer likely is "yes."

United States Tax

CD

Caplin & Drysdale

How Intercompany Agreements Can Mitigate Transfer Pricing Risk

Multinational groups constantly evolve, grow, and consolidate, and operational facts and circumstances always change. Say a growing company decides to expand internationally. It may choose to incorporate new...

United States Tax

MB

Mayer Brown

Proposed Dual Consolidated Loss Rules: More Traps For The Unwary

On August 6, 2024, Treasury and the IRS released proposed regulations that address several long-standing issues related to dual consolidated losses (DCLs) and introduce new rules for "disregarded payment losses" (DPLs).

United States Tax

AM

Alvarez & Marsal

Supreme Court Opens The Doors To Federal Court Challenges To Treasury And IRS Regulations

At the end of its 2023 term, the Supreme Court issued two opinions that will drastically change how taxpayers can challenge Department of Treasury (Treasury)...

United States Tax

SJ

Steptoe LLP

Business Plan For Hollister's India Entry Strategy And Manufacturing Setup

United States Healthcare

Nexdigm USA

Trademark Royalty Free Agreements Tax Considerations

When you hear the term "trademark royalty-free agreement," it means that someone has been given permission to use a trademark without having to pay for it.

United States IP

G.A.M. Law Office

Tax Liability Insurance - M&A And Beyond

During the diligence phase of a transaction, it is not uncommon for a buyer to identify potential tax liabilities that may be caused by a number of situations...

United States Tax

AC

Ankura Consulting Group LLC

Tax, Fraud And The Emergence Of KYC: How Financial Institutions Are Evolving To Face Increasing Threats To Financial Integrity

Financial institutions are facing an increasingly interconnected global financial system, where financial transparency has emerged as a critical element of fiscal systems worldwide...

United States Tax

AM

Alvarez & Marsal

Complex Borrowing And Group Structures

The Court of Appeal's ("CA") ruling in April 2024 in the case of BlackRock Holdco 5 LLC v HMRC ("BlackRock")1 considered the deductibility of interest...

United States Tax

CW

Cadwalader, Wickersham & Taft LLP

Clark Armitage Discusses U.S. Tax Disputes Trends (Podcast)

United States Tax

CD

Caplin & Drysdale

Valuing Legal Entities As Part Of A Legal Entity Rationalization – Key Aspects

United States Tax

AC

Ankura Consulting Group LLC

Logistic Network Optimization

United States Tax

AM

Alvarez & Marsal

Clark Armitage Discusses Cross-Border Transfer Pricing Disputes (Podcast)

United States Tax

CD

Caplin & Drysdale

IRS Updates: ERC Disclosure And Claim Withdrawal Opportunity And Other New Compliance Initiatives

United States Commercial

KR

Kaufman Rossin

Elizabeth Stevens Comments On Increase Staff At The IRS Covering APAs In Bloomberg

United States Tax

CD

Caplin & Drysdale

An Analysis Of Pepsi's Tax Case In Australia: A Look At 'Embedded Royalties' And Diverted Profits Tax

United States Tax

AM

Alvarez & Marsal

Global Tax Risk Program Requires Deep Transfer Pricing Knowledge

United States Tax

F

Fenwick

Successful Approaches To Intellectual Property Valuation

United States Tax

AM

Alvarez & Marsal

IRS Transfer Pricing Memo On Implicit Support Has Legal Flaws

United States Tax

SJ

Steptoe LLP

KPMG Patents Its AI Tool For Transfer Pricing

United States IP

FL

Foley & Lardner

Developing An Effective Transfer Pricing Strategy For Your Business

United States Tax

BT

Bennett Thrasher

Strategies For Overcoming Transfer Pricing Challenges

United States Tax

BT

Bennett Thrasher

Anticipated Increases In Transfer Pricing Enforcement Beginning To Materialize

United States Tax

BT

Bennett Thrasher

10 Key Elements To Consider In A Transfer Pricing Agreement

United States Tax

BT

Bennett Thrasher

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Latest Videos

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The Trouble With Transfer Pricing For Foreign Parents And US Subsidiaries (Video Content)

AF

ArentFox Schiff

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