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
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Transfer Pricing Audits: What Taxpayers Can Do to Prepare
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…
ICAP: Life in the Fast Lane
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…
Happy New Year. Here’s a GLAM on Implicit Support.
“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…
Blowing the Whistle on Transfer Pricing
In a recent case, Villa-Arce v. Commissioner,[1] a whistleblower sent information to the IRS that he believed showed that the company was using improper transfer pricing practices and taking unjustified deductions. The IRS opened an examination that resulted in…
Compliance Campaign: COGS Cops Coming
Last week, the IRS released a mysterious new audit “campaign” that may implicate – inadvertently or otherwise – transfer pricing practices. The campaign, which was announced on August 8, is simply entitled “Inflated Cost of Goods Sold.” …
Liberty Global and the Burden of Proof
In a recent case, the IRS sued a corporate taxpayer in district court for supposedly unpaid taxes—without issuing a notice of deficiency first. The taxpayer claimed that this move was improper, but the district court sided with the IRS. In…
Moore and Pillar Two: Possible Interactions
In Moore v. U.S., Mr. and Mrs. Moore challenge the constitutionality of the transition tax under § 965. The Moores ask the Supreme Court to reaffirm a realization requirement for income taxable under the Sixteenth Amendment. The Moores argue that…
Moore Money, Moore Problems
Today, the Supreme Court decided to hear a case that could have wide-ranging implications on US taxation of income earned abroad. The case challenges a key international provision in the Tax Cuts and Jobs Act: the Section 965 transition tax.…
Mayer Brown Adds to Transfer Pricing Team
Mayer Brown announced today that Sonal Majmudar, former international tax counsel with the Internal Revenue Service (IRS), joined its Tax practice as a partner. Sonal will be resident in the firm’s Washington DC office. Her arrival bolsters Mayer Brown’s market-leading,…