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Topic

Transfer Pricing

302 published works

  1. International Financial Law Prof Blog

    OECD releases BEPS discussion drafts on attribution of profits to permanent establishments

    By William Byrnes

    Public comments are invited on the following discussion drafts: Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 ("Preventing the Artificial Avoidance of Permanent…

  2. SALT Insights

    Transfer Pricing Agreements in State Tax Planning

    By Michael Bowen

    Multistate businesses routinely strive to make their corporate structures more efficient.  This goal often entails forming corporate affiliates with a single functional purpose.  For example, an entity could be formed…

  3. Tax Law for the Closely Held Business

    Why Care About Business Valuation? Part II

    By Lou Vlahos

    Missed Part I?  Check it out here! “Related Party” Transactions Transfer Pricing Valuations figure prominently in determining the proper tax treatment of transactions – such as sales, loans, leases, and…

  4. Tax Controversy 360

    You Must Comply: IRS LB&I Reveals Details of Its Inbound Distributor and OVDP Decline-Withdrawal Campaigns

    By Laura L. Gavioli, PC, Kristina Novak

    On Wednesday, May 10, 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) hosted a webinar with the Association of International Certified Professional Accountants (AICPA) regarding LB&I’s…

  5. Tax Controversy 360

    Canadian Tax Court Holds that Agreements Reached Under the Mutual Agreement Procedure are Binding on the Canada Revenue Agency

    By Steven Hannes, K. Christy Vouri-Misso

    On March 10, 2017, the Tax Court of Canada held that agreements reached under the Mutual Agreement Procedure (MAP) precluded the Canada Revenue Agency (CRA) from redetermining the transfer prices…

  6. International Financial Law Prof Blog

    OECD Seeks to Hire by Summer Head of Tax Treaty Unit – Tax Treaty, Transfer Pricing and Financial Transactions Division

    By William Byrnes

    The CTPA is looking for a highly qualified and dynamic international tax expert to head its Tax Treaty Unit. Treaty-related issues form a significant part of the G20/OECD Project on…

  7. International Financial Law Prof Blog

    Draft Form 8975, Country-by-Country Report, and Schedules A, Tax Jurisdiction and Entity Financial Information for 2017 Filing

    By William Byrnes

    Some jurisdictions have adopted country-by-country (CbC) reporting requirements for annual accounting periods beginning on or after January 1, 2016, that would require a constituent entity resident in the jurisdiction to…

  8. International Financial Law Prof Blog

    IRS LB&I Launches 13 Compliance & Audit Campaigns

    By William Byrnes

    IRS Announces Initial Rollout of Campaigns The IRS Large Business and International division has announced  the identification and selection of 13 campaigns. This is a significant milestone for LB&I in…

  9. International Financial Law Prof Blog

    The Platform for Collaboration on Tax invites comments on a draft toolkit designed to help developing countries address the lack of comparables for transfer pricing analyses

    By William Byrnes

    Responding to a request by the Development Working Group of the G20, the Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN and World Bank…

  10. DLA Piper Latin America – Law Blog

    New transfer pricing requirements in Latin America under BEPS

    By DLA Piper

    This publication first appeared as a Latin America Alert on www.dlapiper.com. Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and…