Topic
Transfer Pricing
302 published works
International Financial Law Prof Blog
Commission decides selective tax advantages for Fiat in Luxembourg and Starbucks in the Netherlands are illegal under EU state aid rules
The EU's Marbury v Madison? Starbucks represents the first salvo by the EU Commission to establish that it has the authority, under a State Aid premise, to step into the…
International Financial Law Prof Blog
OECD Releases All Final BEPS Reports – Links Herein
The OECD presented today the final package of measures for a comprehensive, coherent and co- ordinated reform of the international tax rules to be discussed by G20 Finance Ministers at their meeting…
International Financial Law Prof Blog
More Billion Dollar Transfer Pricing Cases Reported in SEC Filings
As of Dec. 31, 2014, the IRS' International Business Compliance and Transfer Pricing Practice units of LB&I had 1,060 cases under examination, involving 1,890 “income-shifting issues,” with total estimated potential…
SALT Shaker
Royal Treatment: No Evidence that Rent-A-Center’s Intercompany Royalty Payments Distorted Indiana Income
By Mike Kerman and Madison BarnettThe Indiana Tax Court granted summary judgment to Rent-A-Center East, Inc. (RAC), finding that the Department of Revenue’s determination that RAC and two affiliates should…
International Financial Law Prof Blog
IRS Eliminates Appeals Arbitration for Transfer Pricing Cases
Rev. Proc. 2015-44 (September 8, 2015) On September 8, 2015 the IRS released Revenue Procedure 2015-44 that eliminates the transfer pricing Appeals arbitration program of Revenue Procedure 2006-44, 2006-2 C.B. 800.…
International Financial Law Prof Blog
IRS Releases “Overview of IRC 482” Practice Unit With Audit Issues and Guidance
On 28 August the IRS released the International Practice Unit (IPU) "Overview of IRC 482". As part of LB&I International’s knowledge management efforts, Practice Units are developed through internal collaboration…
International Financial Law Prof Blog
IRS Releases Advanced Pricing Agreements New Procedures in Rev Proc 15-40 and 15-41
This morning the US Treasury released the long awaited Advanced Pricing Agreement Procedures. The 13 principal differences between these final revenue procedures and the proposed version of Notice 2013-79 are:…
International Financial Law Prof Blog
Expanding the Profit Split Method to Combat BEPS
Prof. Jeffery Kadet's explains - Why Expansion of the Profit Split Method is Required to Combat BEPS... Recognizing the reality that multinational corporations are centrally managed and not groups of…
SALT Shaker
Not So Fast: ALAS Fails to Attain Sufficient State Support
At the Multistate Tax Commission (MTC) Executive Committee Meeting in Spokane, Washington, the Arm’s-Length Adjustment Service (ALAS) Advisory Group provided an update on its transfer pricing effort. On May 7,…
ContractsProf Blog
New Scholarship from Across the Pond
Post v. Jones (US Supreme Court 1856) – A Protype Early Transfer Pricing Type Case Rupert Macey-Dare University of Oxford - Saint Cross College; Middle Temple; Freshfields Bruckhaus Deringer LLP; Minerva…