Topic
Transfer Pricing
302 published works
International Financial Law Prof Blog
OECD releases BEPS discussion drafts on attribution of profits to permanent establishments
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…
SALT Insights
Transfer Pricing Agreements in State Tax Planning
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…
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…
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…
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…
International Financial Law Prof Blog
OECD Seeks to Hire by Summer Head of Tax Treaty Unit – Tax Treaty, Transfer Pricing and Financial Transactions Division
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…
International Financial Law Prof Blog
Draft Form 8975, Country-by-Country Report, and Schedules A, Tax Jurisdiction and Entity Financial Information for 2017 Filing
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…
International Financial Law Prof Blog
IRS LB&I Launches 13 Compliance & Audit Campaigns
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…
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
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…
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…