Transfer Pricing

Top News

IRS Expert Challenges Data Used In Eaton's Projections

By Molly Moses

An expert witness for the Internal Revenue Service questioned the financial projections prepared by Eaton Corp.'s experts Friday in U.S. Tax Court, saying the data they relied on wasn't available in 2012, when the company took on debt to acquire Ireland-based Cooper Industries, a global electrical products manufacturer, for $13 billion.

Eaton Witnesses Probed About Data Used For Credit Analysis

By Molly Moses

An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.

8th Circ. Denies Medtronic's Bid To Rethink Pricing Ruling

By Natalie Olivo

The Eighth Circuit denied healthcare tech company Medtronic's request to reconsider the court's approach for pricing a licensing agreement with a Puerto Rican affiliate, leaving in place Wednesday a ruling that directed the U.S. Tax Court to give the Internal Revenue Service's method another look.

Eaton Should Have Weighed Borrowing In Europe, Judge Says

By Molly Moses

When it acquired Ireland-based Cooper Industries in 2012, Eaton Corp. should have considered the costs of borrowing in Europe to finance the transaction, Tax Court Judge Albert Lauber said Friday in questioning a former Eaton official.

Judge Questions Transfer Of Eaton's $14B Foreign Asset

By Molly Moses

A U.S. Tax Court judge questioned a former Eaton Corp. official Wednesday about the company's decision to restructure the ownership of a valuable foreign subsidiary when it inverted in 2012, noting that the move placed a $14 billion asset out of the U.S. company's reach.

Switzerland Adopts Tax Treaty With Zimbabwe

By Josh White

Switzerland has adopted the dispatch on the double taxation agreement with Zimbabwe as part of expanding its tax treaty network in the region, the Swiss government announced Wednesday.

Expert Analysis

The Benefits Of Competent Authority In Int'l Tax Disputes

Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.

Taxpayer Considerations For La. Audit Program Participation

While the Louisiana Department of Revenue's recently announced transfer pricing managed audit program could resolve time-consuming, expensive audits for many taxpayers, companies nevertheless need to consider the attendant risks in participation, say Jaye Calhoun and William Kolarik at Kean Miller.

International Tax Reform's Implications For Transfer Pricing

As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

MORE COVERAGE

November 4, 2025 06:15 PM

3M Ruling Highlights Loper Bright's Reach In Axing Tax Regs

November 4, 2025 08:24 PM

Former Eaton CFO Says Bond Investors Needed Reassurance

November 3, 2025 08:31 PM

Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told

November 3, 2025 06:26 PM

Kenya Seeks Input On Regs For Min. Tax, Advance Pricing

October 31, 2025 03:12 PM

OECD Reports Sharp Uptick In Transfer Pricing Dispute Cases

October 31, 2025 05:06 PM