Topic
Transfer Pricing
302 published works
Best Methods
Calculating RAB Shares Following Additional Platform Contributions
In the context of a Cost Sharing Arrangement ("CSA"), Treas. Reg. §1.482-7(c)(1) defines a platform contribution (“PCT”) to be “any resource, capability, or right that a controlled participant has developed,…
SALT Shaker
Potential State Tax Implications of Altera Corp. v. Commissioner
The U.S. Supreme Court recently denied cert in Altera Corp. v. Commissioner. This podcast addresses the Altera decision’s impact on transfer pricing and deference. This podcast also addresses prior state…
SALT Shaker
The Impact of Altera on State Tax Transfer Pricing
By Eric Tresh, Maria Todorova, Justin Brown
On June 22, the US Supreme Court denied Altera Corp.'s petition for certiorari seeking review of the US Court of Appeals for the Ninth Circuit's decision upholding the US Department…
Best Methods
New IRS FAQs on Section 6662 Transfer Pricing Documentation Discuss Best Practices
The IRS recently released informal guidance in the form of “Frequently Asked Questions” discussing its “observations of best practices and common mistakes in preparing transfer pricing documentation” under section 6662.…
Best Methods
Support Among Group Members in Time of COVID-19
By Astrid Pieron, Juan F. Lopez Valek
Many multinational enterprises (“MNEs”) are providing new forms of financial, technical, or other support to group members facing COVID-19-related business issues such as plant (temporary) closures or supply chain disruptions.…
Best Methods
COVID-19 and APAs: APMA Signals Flexible Case-by-Case Approach to Address Special 2020 Transfer Pricing Challenges in APAs
By Jason M. Osborn, Thomas Kittle-Kamp
Responding to the potential disruption created by COVID-19 for transfer pricing arrangements, the Advance Pricing & Mutual Agreement (“APMA”) Program on May 11, 2020, issued informal guidance related to the…
Best Methods
“Mutual Dependence”: Authority for Force Majeure in Transfer Pricing
By Thomas Kittle-Kamp, Anthony D. Pastore
COVID-19 has made force majeure a hot topic in transfer pricing. The idea is that the pandemic was an unexpected development of such power, like a natural disaster, that transfer…
International Trade Law
China Customs Targets Key Industries in Latest Transfer Pricing Enforcement Initiative
By David Stepp, Crowell & Moring
Transfer pricing is a major enforcement priority of China Customs in 2020. In April 2020, China Customs launched a national enforcement action to investigate and audit import transactions between related…
Tax Controversy 360
IRS Guidance Signals More Stringent Scrutiny on Transfer Pricing Documentation
By Alex Cheng-Yi Lee, Andrew R. Roberson, Kevin Spencer
On April 14, 2020, the Internal Revenue Service (IRS) issued informal guidance in the form of frequently asked questions (the “FAQs”), urging taxpayers to strengthen their transfer pricing documentation required…
Disputing Tax
Noteworthy Tax Controversy Events
International Tax Review: Leading Women in Tax Forum: Ropes & Gray is a sponsor of the ITR: Leading Women in Tax Forum on March 3 in New York, New York.…