Transfer Pricing

Top News

Eaton Must Give Up Personnel Docs In Transfer Pricing Probe

By David Hansen

Eaton must comply with an Internal Revenue Service summons for the personnel records of its foreign employees in the government's transfer pricing investigation of the multinational power management company, an Ohio federal judge ruled Thursday.

A Fifth Of Big Cos. Use Tax Transparency Standard, Org. Says

By Kevin Pinner

About a fifth of the largest 1,000 public companies worldwide have voluntarily used a public country-by-country reporting standard created by an international independent standards organization, the nonprofit said Tuesday.

Aussie Senate Faces Separation Of Promoter Penalty, Gas Tax

By Kevin Pinner

The Australian government is poised to double the penalty for corporate promoters of tax avoidance schemes, but it may first have to compromise by separating its bill from another one dealing with a tax on offshore gas exports, according to a legislative report.

Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight

By David Hansen

The U.S. Department of the Treasury did not act arbitrarily when it wrote transfer pricing regulations that allowed the government to disregard foreign legal restrictions on royalty payments when allocating income to 3M from an affiliate, a law professor told the Eighth Circuit on Tuesday.

Microsemi Calls IRS' Penalty Approval 'Woefully Inadequate'

By Molly Moses

An Internal Revenue Service supervisor's sign-off on a transfer pricing penalty for Microsemi was "woefully inadequate" to meet statutory requirements for penalty approval, the semiconductor manufacturer told the U.S. Tax Court.

Gov't Urges 8th Circ. To Uphold 3M's $24M Pricing Adjustment

By Natalie Olivo

The U.S. government asked the Eighth Circuit to uphold a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from 3M's Brazilian affiliate, arguing the company's appeal involves misplaced reliance on a U.S. Supreme Court decision.


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

May 10, 2024 06:59 PM

5 Goals Gov'ts Have For The UN Tax Convention

May 8, 2024 02:31 PM

UN To Publish Draft Terms Of Reference For Tax Pact In June

May 7, 2024 06:00 PM

Industry Groups Suggest Changes To Aussie Reporting Rules

May 4, 2024 01:33 PM

IRS Seeks More Info On Purpose Test In Buyback Tax Regs

May 3, 2024 08:02 PM

US Resisting More Scoping On Amount B, Economist Says

May 3, 2024 05:35 PM

Africa Seeks Early UN Reform On Transfer Pricing, Exchanges

May 1, 2024 07:16 PM

Middle East, North African Gov'ts Back UN For Corp. Tax Talks

May 1, 2024 05:18 PM

UN Must Improve Corp. Tax Rules, Platforms, Some Gov'ts Say

April 29, 2024 02:22 PM

OECD-UN Initiative Lands Developing Countries $2.3B In Tax

April 26, 2024 06:47 PM

4 Goals For Gov'ts To Pursue In The UN Tax Convention

April 23, 2024 05:48 PM

Int'l Pricing Pact Guidance Is Coming Soon, IRS Official Says

April 19, 2024 01:52 PM

Questions Loom Over China's Pillar 2 Participation

April 19, 2024 03:08 PM

India Signs Record Amount Of Advance Pricing Agreements

April 19, 2024 06:49 PM

UN Should Eye Unitary Taxes, DSTs For Tax Pact, Report Says

April 18, 2024 01:11 PM

Transfer Pricing And Dancing: Recalling KPMG's Sean Foley

April 17, 2024 04:06 PM

Aussie Tax Office Misses Transfer Pricing Review Goals

April 16, 2024 06:18 PM

3 Key Takeaways From The IRS' Latest Pricing Pact Snapshot

April 15, 2024 07:34 PM

8th Circ. Urged To Revive IRS' Pricing For Medtronic

April 10, 2024 05:16 PM

EU Parliament Wants Transfer Pricing Rules To Apply Sooner

April 10, 2024 04:01 PM

IRS' DOJ Referral Rules 'A Disaster,' Sen. Whitehouse Says