Topic
Transfer Pricing
283 published works
Tax Controversy 360
IRS Practice Unit Advises Examiners to Use Aggregate Approach in Valuing Outbound Transfers
By Kristina Novak, McDermott Will & Emery
On January 4, 2017, the Internal Revenue Service (IRS) released a new “International Practice Unit” (IPU) on the value of intangibles in IRC Section 367(d) transactions in conjunction with cost…
Disputing Tax
Ninth Circuit Appeal in Altera Could Have Broad Implications for IRS’s Rule-Making Authority
By Kat Gregor
A hotly contested appeal regarding the IRS’s authority to promulgate regulations is underway in the Ninth Circuit. Last year, in Altera Corp. & Subsidiaries v. Comm’r, the Tax Court entered…
Tax Controversy 360
Court Opinions – A Year In Review
Several notable court opinions were issued 2016 dealing with a variety of substantive and procedural matters. In our previous post – Tax Controversy 360 Year in Review: Court Procedure and…
Tax Controversy 360
Transfer Pricing Developments – A Year in Review
Transfer pricing, the allocation of income or loss between members of a controlled group, (TP) continues to be the critical taxation issue in the cross-border world (international, federal or state),…
Tax Controversy 360
Transfer Pricing Compensating Adjustments: Another IRS Loss
Following the resolution of a transfer pricing adjustment, there are inevitable compensating adjustment issues to be addressed. Revenue Procedure 99-32 provides the guidelines. A frequent issue concerns whether the “account”…
International Financial Law Prof Blog
OECD releases further BEPS guidance on Country-by-Country reporting and country-specific information on implementation
The Inclusive Framework on BEPS has released two new documents to support the global implementation of Country-by-Country (CbC) reporting (BEPS Action 13): Key details of jurisdictions' domestic legal frameworks for…
DLA Piper Latin America – Law Blog
Public Consultation RFB No. 011/2016 – BEPS’ Country-by-Country Report
By DLA Piper
By Alex Jorge, tax partner, and Marcelo Siqueira, senior tax associate, of Campos Mello Advogados in Brazil (in cooperation with DLA Piper) On November 7, 2016, the Brazilian Federal Revenue…
Tax Controversy 360
‘Medtronic v. Commissioner’: A Taxpayer Win on Transfer Pricing, Commensurate with Income, and Section 367 Issues
On June 9, 2016, the US Tax Court released its opinion in Medtronic, Inc. and Consolidated Subsidiaries v. Commissioner. The Internal Revenue Service had taken issue with the transfer pricing…
International Financial Law Prof Blog
Several new jurisdictions sign transfer pricing automatic sharing of corporate country-by-country reports and CRS financial information about individuals
As part of continuing efforts to boost transparency by multinational enterprises (MNEs), Brazil, Guernsey, Jersey, the Isle of Man and Latvia signed today the Multilateral Competent Authority Agreement (MCAA) for…
DLA Piper Latin America – Law Blog
Latin American countries focus on new legislation around tax and transfer pricing – independence limitations in Ecuador
By DLA Piper
A recent report published by the United Nations’ Economic Commission for Latin America and the Caribbean (CEPAL) calculated that Latin American countries have lost more than US$98 billion in tax…