Transfer pricing refers to the pricing of goods, services and intellectual property transferred between related entities within a multinational corporation. Companies use transfer pricing to allocate ...
The AICPA provided comments to the IRS on forthcoming proposed regulations that will include the Organisation for Economic Co-operation and Development’s (OECD’s) simplified and streamlined approach ...
Internal Revenue Service sign with a traffic signal in the foreground indicating a red light. The IRS’ recent advice memorandum on periodic adjustments suggests that the agency may belatedly start ...
Transfer pricing remains a strategic focus for multinational corporations, intricately linked to their global tax strategies and compliance frameworks. As businesses expand across borders, the impact ...
This article explores transfer pricing disputes with tax authorities and related disclosures in financial statements. Recent increases in companies’ risk exposure from these controversies have raised ...
August was an exciting month for those who follow U.S. transfer pricing litigation. Courts handed down opinions in the high-stakes, long-running Medtronic MDT Inc. v. Commissioner and Eaton v.