Sections
Companies
Firms
News (1655)
-
May 09, 2019 BEAT Not Limited To Foreign-Owned Biz, Tax Panelists Say
..."If it's transfer pricing appropriate, there's no base erosion evidently involved in that," Ryan said...
-
May 09, 2019 Set APA Objectives At Prefiling Conference, Practitioner Says
...Sean Foley, the global head of transfer pricing dispute resolution at KPMG LLP....
-
May 08, 2019 Old Transfer Pricing Notions Of IP Don't Suit New Biz Models
...by recent changes to the transfer pricing statute....
-
May 06, 2019 Canadian Mining Co. Wins $7.63M In Court Costs From Tax Fight
...In September, the justice rejected a CRA adjustment of transfer pricing costs for tax years 2003, 2005...
-
April 29, 2019 Defining Marketing, Trademark IP Could Sink OECD Tax Plan
...The OECD's transfer pricing manual already defines one as an intangible that "relates to marketing activities...
-
April 22, 2019 Oral Interviews Can't Be Forced In Tax Audits: Canada Court
...However, Paul Mulvihill, a partner in EY's Canadian tax and transfer pricing controversy practice, said...
-
April 22, 2019 US Debate On Fighting Income-Shifting Could Return At OECD
...pricing among the various affiliates in a way that average rate approach does not," Harter said, speaking...
-
April 18, 2019 A First Look At Austria's Digital Services Tax
...pricing rules, the revenue of the group is determinative....
-
April 17, 2019 IRS Division Announces 3 New Compliance Campaigns
...The captive service provider campaign will examine transfer pricing in situations in which a foreign...
-
April 16, 2019 No Settlement In Sight In Perrigo's $163M Tax Row With U.S.
...The IRS hadn't used its methodology to study the transfer pricing aspect of the case, they noted, adding...
-
April 11, 2019 Law360's Tax Authority Federal Editorial Advisory Board
...Mezei focuses largely in the transfer-pricing area and teaches "Survey of Transfer Pricing" in the Graduate...
-
April 10, 2019 Loss Question Could Vex Digital Tax Debate At OECD
...As the Internal Revenue Service learned in its longstanding transfer pricing case against Amazon.com,...
-
April 09, 2019 Law360's Tax Authority International Editorial Advisory Board
...Transfer Pricing," "Money Laundering, Asset Forfeiture and Recovery, and Compliance - A Global Guide,...
-
April 09, 2019 Law360's Tax Editorial Advisory Board
...Kim concentrates his practice in international tax and operational structuring, global transfer pricing...
-
April 08, 2019 Australia Looks To Adjust Rules On Gas Transfer Pricing
...Callaghan's review recommended that the current gas transfer pricing regulations be examined "to identify...
-
April 05, 2019 Tax Advisers Welcome EU Court's Transfer Pricing Ruling
...CFE added that "denial of that opportunity through automatic transfer pricing adjustments would render...
-
April 05, 2019 Silver Co. Can't Yet Buck Investor Suit Over $207M Tax Row
...pricing transactions and the risk of having its tax position invalidated....
-
April 02, 2019 IRS Real-Time Audit Program Launches New Reporting Template
...Best was asked about other transfer pricing initiatives, including a "functional cost diagnostic" model...
-
April 01, 2019 US Delegate To OECD Reports Progress In Digital Tax Work
...Harter outlined some of the options for this approach, including a transfer pricing-based solution and...