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Transfer Pricing

Miller Canfield

Watch the Scope of Your IRS Closing Agreement

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The rules relating to delegated authority are complex. A taxpayer is well advised to ensure that the scope of a closing agreement the taxpayer signs is what the taxpayer expects, and that an IRS official who signs the...more

Ankura

Valuing Legal Entities as Part of a Legal Entity Rationalization – Key Aspects

Ankura on

24 In this article, we delve into the intricacies of valuing individual legal entities as part of a legal entity rationalization, exploring some of the key considerations that must be considered to prepare a robust and...more

Strafford

[Webinar] Tax Treatment of Leveraged Blockers Used by Foreign Investors: Recent IRS Guidance, Deal Structures, Tax Planning - June...

Strafford on

This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more

Barnea Jaffa Lande & Co.

Tax: Classification of Inter company Transactions

A precise definition of business services was recently at the core of a dispute between the Israel Tax Authority and eBay Marketplace Israel Ltd., a subsidiary of the multinational eBay Group. The district court litigated...more

Proskauer Rose LLP

UK Tax Round Up - April 2024

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Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions

The “GILTI Conscience” podcast team, led by partners David Farhat and Nate Carden, hosted Clark Armitage of Caplin & Drysdale for an in-depth conversation on the various methods for resolving cross-border transfer pricing...more

Pillsbury - SeeSalt Blog

South Carolina Legislature Forces New Standards for Forced Combination on Revenue Department

Under a new bill signed into law on March 11, 2024, the South Carolina Department of Revenue will have to satisfy additional standards before it may force affiliated corporate taxpayers to file a unitary combined return. ...more

Alston & Bird

IRS’s Advance Pricing and Mutual Agreement Program Rebounds in 2023: What Is APMA’s Long Game?

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APMA set a record for executed advance pricing agreements (APAs), but high processing times and a hefty pending APA inventory continued to challenge APMA in 2023. Our Federal & International Tax Group evaluates trends gleaned...more

A&O Shearman

Amount B or not to be? The OECD’s Pillar One Amount B report

A&O Shearman on

The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more

International Lawyers Network

Establishing a Business Entity in Lithuania (Updated)

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

International Lawyers Network

Establishing a Business Entity in England (Updated)

The attractiveness of the United Kingdom as a business location is unabated. There are many advantages to doing business in the UK. Investors can draw on a skilled workforce and access a large market; costs of labour and...more

Mayer Brown

Mise à jour de la doctrine administrative relative aux prix de transfert

Mayer Brown on

À la suite de la publication de l’édition 2023 du Guide des prix de transfert à l’usage des PME, l’administration fiscale a mis à jour ses commentaires au BOFiP relatifs aux principes de détermination des prix de transfert...more

International Lawyers Network

Establishing a Business Entity in Brazil (Updated)

The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they ...more

International Lawyers Network

Establishing a Business Entity in Argentina (Updated)

Types of business entities - The two most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”) and the corporation (“Sociedad Anónima” or...more

A&O Shearman

The EU Transfer Pricing Directive: the Commission looks to harmonise TP across the EU

A&O Shearman on

The TP Directive’s stated goal is to increase tax certainty, reduce compliance costs, and mitigate the risk of double-taxation and litigation for cross-border intra-group transactions within the EU. The TP Directive would...more

Hogan Lovells

Complemento carta porte

Hogan Lovells on

El domingo 16 de julio de 2023 se publicó la Primera Versión Anticipada a la Sexta Resolución de Modificaciones a la RMF para 2023, en el que se estableció que el uso del CFDI con complemento Carta Porte será aplicable a...more

A&O Shearman

UK considers changes to rules on transfer pricing, permanent establishments and diverted profits tax

A&O Shearman on

HMRC has published a consultation paper anticipating reforms to the UK’s rules on transfer pricing, permanent establishments and diverted profits tax. This is a wide-ranging review and it may be that its constituent parts...more

Alston & Bird

What to Make of the IRS’s New “Gatekeeping” Guidance for Advance Pricing Agreements

Alston & Bird on

Our International Tax Group unpacks recent IRS guidance and public comments that reveal how the agency is changing its advance pricing agreement (APA) procedures. The Large Business and International Division released a...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Issues Interim Guidance to Staff on Reviewing and Accepting Advance Pricing Agreement Submissions

The Internal Revenue Service (IRS) recently released instructions for employees that may have the effect of deterring some companies from submitting advance pricing agreement (APA) requests. That, in turn, could introduce...more

Holland & Knight LLP

The New IRS Selectivity Criteria for Advance Price Agreements and Renewals

Holland & Knight LLP on

The IRS has announced new rules relating to the acceptance of Advance Pricing Agreement (APA) and renewal requests. On April 25, 2023, the IRS published interim guidance (the Interim Guidance), effective as of that date, that...more

Alston & Bird

Searching for “Green Shoots” After a Difficult Year for IRS’s Advance Pricing and Mutual Agreement Program

Alston & Bird on

Last year’s historic demand with a smaller staff compounded 2021’s challenges for the Advance Pricing and Mutual Agreement Program (APMA). Our International Tax Group delves into this year’s annual report to evaluate trends...more

Eversheds Sutherland (US) LLP

IRS issues annual Advance Pricing Agreement Report for 2022

On March 27, 2023, the Internal Revenue Service (IRS) issued its Announcement and Report Concerning Advance Pricing Agreements (APA Report) for 2022, which presents the key APA results of the IRS’s Advance Pricing and Mutual...more

International Lawyers Network

Establishing A Business Entity In Lithuania (Updated)

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

International Lawyers Network

Establishing A Business Entity In England (Updated)

The attractiveness of the United Kingdom as a business location is unabated. There are many advantages to doing business in the UK. Investors can draw on a skilled workforce and access a large market; costs of labour and...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | An In-Depth Look at International Tax in Africa: Part 1

In the first of a two-part “GILTI Conscience” series, we detail transfer pricing across the African continent, as well as taxation in the region generally. Skadden partners Nate Carden and David Farhat and associates Mayté...more

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