United States: Transfer Pricing

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Supplementary Law No. 225/2026: Taxpayers' Defense Code

On January 9, 2026, the final text of the Supplementary Law ("LC") No. 225/2026 was published in the Official Gazette of the Federal Government, which launches the Taxpayers´ Defense Code (the "Code").

United States Tax

MB

Mayer Brown

Recent IRS Guidance On Branch Profits Tax Treaty Benefits For Foreign Reverse Hybrid Entities

The IRS recently issued a Chief Counsel Advice Memorandum (AM 2025-002) that provides helpful guidance regarding the application of the branch profits tax in connection with reverse foreign hybrid entities and U.S. income tax treaties with foreign countries.

United States Tax

FL

Foley & Lardner

The New Pillar Two Framework: Unboxing The Side-By-Side Package

On January 5, 2026, the OECD Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS) released the highly anticipated Side-by-Side (SbS) package.

AM

Alvarez & Marsal

A&M Tax Policy Insights – November 2025

The Global Tax Policy and Controversy (TPC) Group at A&M Tax is pleased to bring you this month's edition of our newsletter, A&M Tax Policy Insights.

AM

Alvarez & Marsal

Transfer Pricing Issues When Dealing With Trusts, Foundations, And Similar Arrangements

United States Tax

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NERA

EU Tax Directives #6 Repeal Of 3 Proposed EU Tax Directives - New York Office Snippet

United States Tax

LL

Loyens & Loeff

Commentary On New Canadian Transfer Pricing Legislation

United States Tax

RP

Ruchelman PLLC

What Landmark Israeli Transfer Pricing Case, Hexadite Ltd. v. Israel Tax Authority, Means For U.S. Multinationals

United States Tax

RS

Rotfleisch & Samulovitch P.C.

FAQ: How Tax And Tariff Changes Are Impacting Manufacturing CFOs

United States Tax

MG

MGO CPA LLP

U.S. Tax Shifts And Tariff Volatility: What Manufacturing CFOs Need To Know

United States Tax

MG

MGO CPA LLP

U.S. Reporting Requirements For Cross-Border, Related-Party Transactions: What U.S. Taxpayers Must Know Now For Compliance

United States Tax

RS

Rotfleisch & Samulovitch P.C.

A&M Middle East Tax & Customs Newsletter | Fall Edition

AM

Alvarez & Marsal

Why The IRS Just Made It Easier To Reduce BEAT Exposure On Intercompany Services

United States Tax

MG

MGO CPA LLP

トランプ関税への対応と移転価格への影響

United States Tax

JD

Jones Day

Food Venture Financing News – Weekly Issue No. 265

United States Healthcare

DW

Davis Wright Tremaine

The X Factor In Mediation Success: Why A Consistent Client Experience (CX) Fosters Trust

United States Litigation

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JAMS

Colorado "Opt-Out" Litigation – Petition For Rehearing En Banc And Amicus Briefs In Support

United States Finance

BS

Ballard Spahr LLP

How The GENIUS Act Is Reshaping Stablecoin Regulation And Emerging Financial Disputes

United States Litigation

J

JAMS

Federal Circuit: Priority Document That 'Broadly Outlines' Possible Structures Fails To Provide Adequate Written Description Support For Subgenus Of Linkers In Antibody-Drug Conjugate

United States IP

AG

Akin Gump Strauss Hauer & Feld LLP

Still Fourth Down And Goal For Medtronic Transfer Pricing Case

In an article published in Insights in 2022, the following comment was made regarding two seemingly never-ending transfer pricing battles being conducted...

United States Tax

RP

Ruchelman PLLC

Tax Law Changes That Should Trigger Referrals For Your Clients

The One Big Beautiful Bill Act (OBBBA) is the latest sweeping change to the tax code—and one that advisors can't afford to ignore.

United States Tax

KR

Kaufman Rossin

How To Align Your Global Supply Chain And International Tax Strategy

Aligning international tax strategy with global supply chain planning helps reduce tax exposure, capture incentives, and increase operational agility.

United States Tax

MG

MGO CPA LLP

5 Quick Questions For Referrers: How Specialty Tax Adds Value For Your Clients

Want to know where specialty tax providers can plug in to help your clients—and where they don't? These frequently asked questions provide clarity for accountants...

United States Tax

KR

Kaufman Rossin

Frequently Asked Questions About International Tax And Supply Chain Realignment

United States Tax

MG

MGO CPA LLP

Amendments To The German Regulation On The Attribution Of Profits To Permanent Establishments (Betriebsstättengewinnaufteilungsverordnung) Relating To Insurance Permanent Establishments

United States Tax

AM

Alvarez & Marsal

Eaton's Loss To IRS Sparks Concerns Over EU Privacy Compliance

European Union Privacy

KR

Kaufman Rossin

Navigating Q2 2025: Essential Income Tax Accounting Insights

AM

Alvarez & Marsal

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

United States International

HS

Harris Sliwoski

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

United States Tax

CL

Carter Ledyard & Milburn

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

United States Tax

WR

Wiley Rein

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

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

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.

The Trump administration has recently advanced a series of initiatives that significantly expand the scope of U.S. economic protectionism, targeting foreign tax practices perceived as discriminatory against American interests.

United States Tax

GW

Gowling WLG

Navigating Tariffs And Income Taxes And Transfer Pricing

In this new trade landscape, it is more important than ever to coordinate customs and operational planning with 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

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

Dans une décision qui sera mentionnée aux tables du Recueil Lebon, le Conseil d'Etat apporte des précisions relatives au régime...

European Union Tax

MB

Mayer Brown

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

On Feb. 19, 2024, the Organization for Economic Cooperation and Development (OECD) amended its transfer pricing guidelines to include "Amount B," a standardized approach...

GT

Greenberg Traurig, LLP

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

The IRS has issued guidance providing for a "simplified and streamlined approach," or SSA, to transfer pricing for marketing and distribution activities that is expressly reliance-eligible for taxable years beginning on or after January 1, 2025.

United States Tax

CD

Caplin & Drysdale

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

United States Tax

N

NERA

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

United States Tax

N

NERA

IRS Issues Final Rules On Intangible Property Repatriations

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

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

United States Healthcare

Nexdigm USA

Project Management For Winding Down Operations In India

United States Media & IT

Nexdigm USA

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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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