United States: Transfer Pricing

Transfer pricing complexities emerge as artificial intelligence systems increasingly rely on vast training datasets, raising critical questions about how multinational corporations should value and allocate these intangible assets across jurisdictions. The intersection of AI development and international tax law presents novel challenges for determining arm's length pricing when data crosses borders within corporate structures.

Selling an S corporation involves complex tax and legal considerations that can significantly impact after-tax proceeds. This comprehensive analysis examines stock sales versus asset sales, IRC Section 338(h)(10) elections, F reorganizations, and other transaction structures, revealing how different approaches affect both sellers and buyers through detailed tax modeling and strategic planning insights.

The One Big Beautiful Bill Act (OBBBA) has reshaped tax incentives for wineries, expanding opportunities for R&D expense deductions, production property depreciation, and energy credits. Understanding how these changes interact with winery operations—from fermentation systems to facility upgrades—can significantly impact cash flow and investment returns. This framework helps wineries align tax planning with operational decisions to maximize available benefits.

While most transfer pricing rules will apply to large multinational enterprise (MNE) groups, family offices, foundations, and trusts cannot ignore them.

Loyens & Loeff New York regularly posts ‘Snippets' on a range of EU tax and legal topics. Earlier this calendar year, our ‘EU Tax Directives Series' offered practical, concise summaries of key EU tax directives...

The November 4, 2025, Canadian federal budget introduced new Canadian transfer pricing legislation containing the most consequential change since 1997.

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...

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...

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...