
In January, the IRS issued a generic legal advice memo on periodic adjustments and the arm’s length standard. Although the “GLAM” states that it merely “clarifies” and “updates” a prior memo, it contains insights into the IRS’s aggressive thinking
In January, the IRS issued a generic legal advice memo on periodic adjustments and the arm’s length standard. Although the “GLAM” states that it merely “clarifies” and “updates” a prior memo, it contains insights into the IRS’s aggressive thinking…
Last week, the US Treasury released long-awaited proposed regulations on the corporate alternative minimum tax or “CAMT.” In a press release, Treasury estimated “that around 100 of the largest and most profitable companies will pay the CAMT annually.” According…
On March 22, 2024 the IRS’s Advance Pricing Mutual Agreement Program (“APMA” or the “Program”) released Announcement 2024-16 which provides their annual Advance Pricing Agreement (“APA”) report (the “Report”), and the statistics show a record-breaking result for 2023 – 156…
On February 19, 2024, the OECD Inclusive Framework on BEPS published its long-awaited final report on Pillar One – Amount B.[i] The report details guidance on the “simplified and streamlined approach” (formerly known as Amount B) for…
The IRS has made it clear once again that transfer pricing remains a key focus in its ongoing enforcement efforts.[1] And with significant additional resources to do so over the next decade, the IRS is likely to focus…
On January 29, 2024, the OECD released the results and statistics for its growing International Compliance Assurance Program (“ICAP”).[1] The data spans the life of the ICAP program, dating back to the first pilot program that began in January…
“Implicit support” comes charging out of the gates as an early candidate for Word or Phrase of the Year for 2024.
Before year’s end, the IRS Office of Chief Counsel dropped a new generic legal advice memorandum (“GLAM”), AM 2023-008…