Transfer Pricing

By Josh White

European Union member states are losing €14 billion ($16.5 billion) in revenues each year as a result of tax avoidance by U.S. companies, Tax Justice Network warned Monday ahead of international tax talks.

By Molly Moses

It's not easy being an expert witness in a U.S. Tax Court case. Lawyers ask leading questions and bring up old research; hypothetical scenarios abound, requiring analysis on the fly; and judges have varying levels of expertise, with some seeking detailed explanation and others offended by it.

By Molly Moses

The Eighth Circuit's ruling that Brazilian law prevented the IRS from reallocating income to 3M from its subsidiary in that country "makes no sense" because the law limits only royalties, not other forms of income, the government argued Thursday in seeking a rehearing by the full court.

By Anna Scott Farrell

Semiconductor manufacturer Microsemi has agreed to report $144 million in income from sales to its Irish affiliate but will avoid some tax penalties under the terms of a transfer pricing settlement with the Internal Revenue Service, according to a filing in the U.S. Tax Court.

By Molly Moses

Pharmaceutical giant Perrigo overpaid $89.2 million in taxes, penalties and interest during years 2009 through 2012, a Michigan court found in a final judgment issued Tuesday.

By Kevin Pinner

The United Nations released an updated template for the framework convention on international tax cooperation with more descriptive wording on allocating taxing rights, a new article on exchange of information and trimmed commitments on harmful tax practices.