Transfer Pricing

Top News

Tax Pros Say Gov'ts Stretching 'Realistic Alternative' Analysis

By Molly Moses

Tax authorities including the Internal Revenue Service are overstepping in their use of "realistic alternative" arguments, substituting their own judgment for that of businesses, transfer pricing specialists said Thursday.

Most Top US Cos. To Report Tax Under Aussie Bill, Study Says

By Kevin Pinner

Australia's Senate is expected to consider adoption next month of the world's most extensive public country-by-country reporting rules, which would require 51% of large U.S. multinational corporations to disclose tax arrangements retroactively from July 1, according to a study published Thursday.

Top International Tax Cases To Watch In The 2nd Half Of 2024

By Natalie Olivo

Tax attorneys will be tracking several high-stakes cases in the second half of 2024 that could define the bounds of the IRS' ability to craft regulations or lodge direct challenges aimed at what it sees as the tax avoidance maneuvers of multinational corporations. Here, Law360 looks at key international tax cases to follow during the rest of the year.

Treasury Starting To Address Amount B, Official Says

By David van den Berg

The U.S. Department of the Treasury is just starting to decide how to handle a transfer pricing regime under a prong of the OECD-led global tax overhaul, a Treasury official said Thursday.

IRS Plans August Hearing On Stock Buyback Tax Rules

By Jack McLoone

The Internal Revenue Service will hold a public hearing Aug. 27 on proposed regulations governing a new excise tax on repurchases of corporate stock, the agency said Wednesday.

Aussie Gov't Seeks Tighter Promoter Penalties After PwC Leak

By Kevin Pinner

Australia is poised to penalize a wider range of advisers who promote tax schemes to multinational corporations and beef up its Tax Practitioners Board's ability to investigate cases after it uncovered PwC sharing confidential draft laws with clients, according to a consultation that began 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.


July 17, 2024 05:59 PM

Gov't Views On OECD Risk Guidance Vary, Economists Say

July 16, 2024 07:33 PM

More Geographic Adjustments 'On The Table' For Amount B

July 16, 2024 08:58 PM

Intracompany Prices Should Reflect Acquired IP, Panelists Say

July 16, 2024 05:08 PM

EU Opposed Fast-Tracking Reforms Under UN Tax Convention

July 12, 2024 08:54 PM

Chevron's End Doesn't Bear On 3M's Case, IRS Tells 8th Circ.

July 11, 2024 02:48 PM

Tax Haven Biz Revenues Per Worker Still Far Outpace Norm

July 5, 2024 04:04 PM

Tractor Supply Incorrectly Shifted Income, SC Tells Court

July 5, 2024 11:08 AM

Top Federal Tax Cases To Watch In The 2nd Half Of 2024

July 2, 2024 04:57 PM

Eaton Needs To Cough Up Docs In IRS Probe, US Says

July 1, 2024 02:19 PM

OECD Tax Chief Affirms Pillar 1 Progress As Deadline Passes

June 28, 2024 01:21 PM

EU Leaders Nominate President Von Der Leyen For 2nd Term

June 27, 2024 06:23 PM

Aussie Betting Site Can't Duck Taxes Tied To News Corp. Sale

June 27, 2024 06:21 PM

High Response To IRS Transfer Pricing Letters, Official Says

June 25, 2024 11:57 AM

New EU Chair Hungary Eyes Talks On Corp. Tax, But No Deals

June 24, 2024 12:07 PM

EU States Turn Down Transfer Pricing Proposal, Report Says

June 24, 2024 05:39 PM

Loss Guidance Will Cover Pillar 2, IRS Official Says

June 17, 2024 06:05 PM

OECD Tax Plan Is Developing Nations' Best Choice, Prof Says

June 14, 2024 06:54 PM

Eaton Says Court Improperly Required Int'l Employee Evals

June 14, 2024 06:44 PM

Mining Co. Entity Can't Deduct Loan Interest, UK Court Says

June 12, 2024 05:41 PM

Groups Push Back On Stock Buyback Tax Test's Scope