Arm's Length Principle Vs. Implicit Support: What's the Way Forward?
The Liberty Global Inc. v. United States appeal has practitioners and taxpayers concerned that the economic substance doctrine will be applied to disallow the tax benefits of ordinary course of business decisions and disrupt...more
Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the...more
A recent disclosure by the Indiana Department of Revenue shows that a trend toward states engaging in transfer pricing in earnest is gaining traction. This shift requires a change in approach to defending intercompany...more