Topic
Transfer Pricing
255 published works
Best Methods
Standard of Review in Transfer Pricing Litigation
By John T. Hildy, Anthony D. Pastore, Tyler M. Johnson
A recent Tax Notes article analyzes the “standard of review” that the Tax Court will apply to the IRS’s transfer pricing adjustments. In transfer pricing cases, the Tax Court determines…
Best Methods
Intercompany Services: The Next Frontier of Transfer Pricing Disputes
By Jenny A. Austin, Elena B. Khripounova
In the dawn years of transfer pricing, when the bulk of international trade focused on tangible goods, relatively little attention was devoted to the analysis of transactions involving services. The…
Best Methods
Document Preservation for Transfer Pricing Litigation: What You Need to Know
By Jenny A. Austin, Anthony D. Pastore
Assume the Internal Revenue Service (“IRS”) is auditing your company’s transfer pricing. The administrative process is starting to break down, and it looks as if the IRS might assert a…
SALT Shaker
California’s attempt to extend transfer pricing to sales tax
By Eric Tresh, Timothy Gustafson, Elizabeth Cha
Sales taxes are imposed by all but five states. While the types of sales that are subject to tax vary significantly by state, virtually all sales tax states look to…
Milikowsky Tax Law Blog
Form 5472 Foreign Owned Company Filings
One important aspect of being a business owner is ensuring that you keep up with changing laws and regulations that may be applicable to your business. There are consistent changes…
SALT Shaker
Transfer pricing and its effects on state tax
In this episode of the SALT Shaker Podcast, host and Associate Chris Lee is joined by Associate Justin Brown to discuss transfer pricing and how it affects state tax and…
Best Methods
ICAP, a New Tool in the Multiverse of Multinational Tax Dispute Management
By Shawn R. O'Brien, Jason M. Osborn, Michael Lebovitz, Tyler M. Johnson
In February 2021, the Organisation for Economic Co-operation and Development (“OECD”) issued a handbook linked with the official roll-out of its International Compliance Assurance Programme (“ICAP”). ICAP was first introduced…
Best Methods
Singapore’s Transfer Pricing Guidance for Centralized Activities of MNEs
The Inland Revenue Authority of Singapore (“IRAS”) has issued transfer pricing guidance for centralized activities of multinational enterprise (“MNE”) groups in Singapore to assist taxpayers in analysing such activities between…
International Trade Law
Advance Pricing Arrangement in China: An Effective Tax Planning Tool for Multinational Companies
The China State Taxation Administration (“STA”) recently published its eleventh “China Advance Pricing Arrangement Annual Report (2019)” that summarized the circumstances under which the STA signed advance pricing arrangements (“APA”)…
Best Methods
OECD’s Pillar One Blueprint: Amount B
Amount B aims to standardize the remuneration of related party distributors that perform baseline marketing and distribution activities in a manner that is aligned with the arm’s length principle. Its…