GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
GILTI Conscience Podcast | An In-Depth Look at International Tax in Africa: Part 1
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis
Musings on Multinational Tax: What to Expect From GILTI Conscience
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
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
The New Jersey Division of Taxation (Division) has announced a “voluntary” transfer pricing initiative beginning June 15, 2022, and continuing through March 2, 2023. According to the Division, the initiative is targeted...more
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
Several years ago, it came to light that the Internal Revenue Service (IRS) had hired a law firm to assist with transfer pricing matters in an ongoing audit of a large corporate taxpayer. Contemporaneous with that hiring, the...more
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
As state revenue agencies train their auditors in traditional IRC §482 transfer-pricing methodologies or outsource transfer-pricing audits to third-party specialists, a recent initiative by the Indiana Department of Revenue...more
Chinese customs authorities have stepped up transfer pricing enforcement in recent years. Here are some of the steps multinational companies should take to address the enforcement risks....more
The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more
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 partnership ...more
Serving as a roadmap for how the Internal Revenue Service intends to conduct transfer pricing examinations, the recently released Transfer Pricing Examination Process guide provides a set of processes and practices for the...more
The Internal Revenue Service has increased its scrutiny of inter-company pricing practices of taxpayers with foreign affiliates and has provided agents conducting audits with standard language requesting information about...more
Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more
Executive Summary - ..Multistate Tax Commission (MTC) transfer pricing program moving forward in some fashion; ..Priority includes information sharing among participating states (and possibly their third party...more
In This Issue: - Fifth Circuit Ruling in BMC Software, Inc. v. Comm’r. Is Good News for Taxpayers - When Is a Second Inspection Not a Second Inspection? - Captive Insurance Litigation: Key 2014 Cases ...more
Deputy Executive Director Greg Matson (a nice guy at heart) announced this week that the Multistate Tax Commission (MTC) has hired its first transfer pricing training consultant and is scheduled to begin training state...more
At its Fall Meeting in Nashville, Tennessee on December 11-12, the MTC’s Executive Committee voted to formally contact states to solidify whether there is sufficient financial commitment to fund any potential MTC transfer...more
On October 6, 2014, the Multistate Tax Commission (MTC) held the first day of a two-day meeting intended to educate state revenue authorities on corporate income tax issues surrounding intercompany transactions, and further...more
On July 15, 2014, the Connecticut Department of Revenue Services awarded Chainbridge Software LLC a contract worth $50,000 for on-site and remotely supported training for transfer pricing audits. Chainbridge is infamous for...more
On June 25, the Arm’s Length Adjustment Services Advisory Group (the Group) of the Multistate Tax Commission (MTC) met via teleconference to continue the process of developing a multistate arm’s length pricing adjustment...more
On June 2, the Arm’s Length Advisory Group (the Group) of the Multistate Tax Commission (MTC) met in St. Louis, Missouri, to begin the process of developing a multistate arm’s length pricing adjustment service. States...more
The Multistate Tax Commission plans to announce that they are accelerating their development of a transfer pricing audit program by soliciting the assistance of Dan Bucks, the former MTC Executive Director and Montana...more
On Thursday, May 9, the Multistate Tax Commission (MTC) hosted an Executive Committee (Committee) meeting in Washington, D.C. The Committee discussed many items ranging from election of new officers to Committee updates to...more