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Transfer Pricing

283 published works

  1. 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…

  2. 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…

  3. Tax Controversy 360

    Court Opinions – A Year In Review

    By Editorial Team

    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…

  4. Tax Controversy 360

    Transfer Pricing Developments – A Year in Review

    By McDermott Will & Emery

    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),…

  5. Tax Controversy 360

    Transfer Pricing Compensating Adjustments: Another IRS Loss

    By McDermott Will & Emery

    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”…

  6. International Financial Law Prof Blog

    OECD releases further BEPS guidance on Country-by-Country reporting and country-specific information on implementation

    By William Byrnes

    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…

  7. 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…

  8. Tax Controversy 360

    ‘Medtronic v. Commissioner’: A Taxpayer Win on Transfer Pricing, Commensurate with Income, and Section 367 Issues

    By Emily Townsend

    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…

  9. 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

    By William Byrnes

    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…

  10. 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…