United States: Transfer Pricing

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

With the return of 100% bonus depreciation, CFOs can now offset capital investments faster and improve post-tax ROI.

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

In Canada, taxpayers must file CRA Form T106 to disclose certain non-arm's length transactions with non-residents. The United States does not have a single consolidated disclosure form equivalent to T106.

United States Tax

RS

Rotfleisch & Samulovitch P.C.

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

We are delighted to present the Fall Edition of our A&M Tax & Customs Newsletter. This edition offers timely insights and key analyses of the most significant tax and customs regulatory developments from the past quarter...

AM

Alvarez & Marsal

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

The IRS has confirmed that the BEAT SCM exception can apply, even when SCM is not used as the primary transfer pricing method.

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

Still Fourth Down And Goal For Medtronic Transfer Pricing Case

United States Tax

RP

Ruchelman PLLC

Tax Law Changes That Should Trigger Referrals For Your Clients

United States Tax

KR

Kaufman Rossin

How To Align Your Global Supply Chain And International Tax Strategy

United States Tax

MG

MGO CPA LLP

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

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

Top 5 Takeaways From "Advanced Mediation Strategies For Handling The Toughest Situations"

United States Litigation

J

JAMS

California Air Resources Board Publishes Draft SB 261 Guidance

United States Commercial

RG

Ropes & Gray LLP

What Honeybees Have Taught Me About Dispute Resolution

United States Litigation

J

JAMS

What Foundations And Other Nonprofits Need To Know About The Foreign Agents Registration Act

United States Government

W

WilmerHale

Back To School 2025: Title IX Updates And How ADR Can Help Universities Resolve Disputes (Podcast)

United States Litigation

J

JAMS

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.

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

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

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

United States Tax

MG

MGO CPA LLP

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

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

In today's global tax environment, transfer pricing has become a critical focus for tax authorities. With multinational companies operating across multiple jurisdictions...

United States Tax

MG

MGO CPA LLP

The Aftermath Of Ya Global: Who Is A Partner?

The YA Global case has drawn widespread attention due to the U.S. tax implications for foreign investment entities investing in U.S. securities or making use of a U.S. investment manager.

United States Tax

RP

Ruchelman PLLC

Transfer Pricing: Insights For The Alternative Investment Industry

In its recent strategic operating plan update, the Internal Revenue Service ("IRS") delineated its future priorities, notably an enhanced audit focus targeting high-net-worth individuals, multinational

United States Tax

ML

Marcum

Tax Year 2024 Changes, Planning For Businesses To Consider

Although only a few areas of tax law had significant changes for 2024, many companies experienced operational and economic changes that could change their tax strategies. Here are a few considerations to keep...

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

Entity Management And Finance, Tax, And Corporate Compliance Support

United States Tax

Nexdigm USA

Finance Function Transition And Management For The Client's Indian Operations

United States Technology

Nexdigm USA

The GenAI Revolution In Biology And Biotech

United States Tax

AM

Alvarez & Marsal

Trademark Royalty Free Agreements Tax Considerations

United States IP

G.A.M. Law Office

Tax Liability Insurance - M&A And Beyond

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

United States Tax

AM

Alvarez & Marsal

Complex Borrowing And Group Structures

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

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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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