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News (1658)
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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....
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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...
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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...
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April 01, 2019 Transfer Pricing Enforcement Still IRS Priority, Rettig Says
...The results of individual transfer pricing cases don't matter as much as continued enforcement in the...
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April 01, 2019 OECD's Trademark Tax Plan Needs To Be More Manageable
...The proposal entails a complicated transfer pricing method that involves splitting residual profits,...
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March 29, 2019 Proposed Foreign Income Tax Regs Were Worth The Wait
..."Benefit" is a defined term cross-reference to the Section 482 (transfer pricing) regulations....
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March 28, 2019 New APA Tool Doesn't Target Particular Cos., IRS Official Says
...pricing guidance that favors use of the tool....
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March 28, 2019 Blockchain Havens Could Be Next Global Tax Challenge
...pricing standards, and the U.S....
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March 28, 2019 OECD Body Urges Work On Report Standard For Gig Economy
...pricing, among other issues....
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March 27, 2019 Record Number Of US Companies Sought APAs In 2018
...But Hughes said the "current uncertainty across the transfer pricing landscape" also played a role....
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March 21, 2019 TCJA Could Trip Up Companies With Loss Years
...pricing right, so it always has some tested income."...
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March 20, 2019 Canada Budget Funds Crackdown On Property-Driven Tax Fraud
...Another would be to amend the act so that "transaction" is defined the same way in transfer pricing rules...
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March 19, 2019 IRS Rolling Over On Penalties, Safe Harbors, Ex-Official Says
...The IRS is giving up revenue unnecessarily by failing to assert transfer pricing penalties in audits...
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March 15, 2019 Stock Options Must Be Treated As Real Cost, Ex-IRS Counsel Says
...pricing Kenneth Wood told Law360 in a recent interview....
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March 13, 2019 OECD's Trademark Tax Proposal Raises Treaty Issues, Pros Say
...pricing guidelines, which could be rewritten....
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March 12, 2019 Tax Court Should Use Its Own Experts, Ex-IRS Counsel Says
...The longtime international tax and transfer pricing specialist spoke with Law360 recently about transfer...
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March 08, 2019 Ex-IRS Official Sees Revenue Grab In New Taxing Approaches
...Arguments that traditional arm's-length transfer pricing unfairly deprives some countries of revenue...
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March 08, 2019 Kenneth Wood Looks Back On 3 Decades In International Tax
...Transfer Pricing Penalties How is the IRS applying transfer pricing penalties?...
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March 07, 2019 'Arm's-Length' Not All About Comparables, IRS Official Says
...A comparability analysis is just one of the tools provided in the U.S. transfer pricing regulations to...
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March 06, 2019 Changes To IRS Audit Process Anticipate Foreign Disputes
...New requirements that IRS examiners conducting transfer pricing audits consult with Advance...