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Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?

Despite adding personnel and making a concerted effort to speed up the advance pricing agreement process, the Advance Pricing and Mutual Agreement Program (APMA) faces challenges with the mounting demand. Our International...more

Risky Business – Allocating Losses When Your Supply Chain Is Disrupted

Can a parent take on losses? Or should the subsidiary incur losses due to risks it assumed? Our International Tax Group investigates the nuances of regulations from U.S. and international agencies and offers actions...more

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