November 8, 2023 06:39 PMCoke Stuck With $882M Adjustment For Brazilian IP Transfers
By David van den Berg
Three senators pressed KPMG's CEO on allegations the company helped Microsoft skirt nearly $29 billion in taxes by illegally allocating profits to a Puerto Rico subsidiary and demanded additional information on KPMG's role in the arrangement.
By Jack McLoone
The OECD and 16 West African nations have collaborated on three so-called community tax instruments to help the region fight base erosion and profit shifting in hope of improving their local economies, according to a report released Wednesday.
By Paul Williams
The U.S. Supreme Court's declining to hear an energy company's claims that Michigan unconstitutionally taxed gain generated from the sale of an out-of-state business highlights open questions about when alternative apportionment should be used to tax income from multistate entities.
By Todd Buell
The European Union doesn't intend to speak for member countries in international discussions about transfer pricing standards, a European Commission official said Wednesday, discussing a new draft law.
By Kevin Pinner
Results presented Tuesday on a multilateral program to resolve transfer pricing issues show it is a viable option for companies, especially as a first step toward tax certainty, an IRS transfer pricing official said.
By Dylan Moroses
The Internal Revenue Service is sending letters to large U.S. partnerships, flagging possible tax reporting issues amounting to millions of dollars, the commissioner of the agency's Large Business and International division said Wednesday.
Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.
While the Louisiana Department of Revenue's recently announced transfer pricing managed audit program could resolve time-consuming, expensive audits for many taxpayers, companies nevertheless need to consider the attendant risks in participation, say Jaye Calhoun and William Kolarik at Kean Miller.
As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.
November 8, 2023 07:09 PMTransfer Pricing Rules Can Simplify Process, EU Advisers Say
November 8, 2023 07:30 PMConocoPhillips Owes $390M In Transfer Pricing Row, La. Says
November 7, 2023 04:54 PMOver 200 Groups Call For UN Global Tax Treaty By Mid-2025
November 6, 2023 05:19 PMOECD Seeks Comments On Transfer Pricing For Lithium
November 1, 2023 06:02 PMJapan, Greece Sign Their 1st Double-Tax Treaty
October 30, 2023 05:53 PMUS Treasury Official Says DST Pause Should Continue
October 30, 2023 06:19 PMArgentina Has Digital Withholding Tax Ready, Official Says
October 26, 2023 03:45 PMOECD Details Withholding Tax Treatment In Profits Plan
October 25, 2023 04:23 PMUS Review Of OECD Multilateral Treaty May Impede Effort
October 24, 2023 08:48 PMStates Should Consider Bilateral Pricing Programs, Atty Says
October 20, 2023 02:14 PMUS, Chile Working To Finalize Tax Treaty, Official Says
October 20, 2023 02:02 PM3 Lingering Issues Under New Int'l Transfer Pricing Plan
October 19, 2023 05:46 PMIndia's High Court Restricts Some OECD Tax Treaty Perks
October 19, 2023 06:31 PMIreland's Proposed Min. Tax To Have Extra Safe Harbor
October 18, 2023 06:09 PMChina Signs Tax Treaties With Cameroon, Senegal
October 18, 2023 05:32 PMSen. Warren Presses Microsoft On $29B IRS Tax Bill
October 18, 2023 06:15 PMAustralia Seeks Comments On Limits To Debt Deductions
October 16, 2023 03:13 PMOECD's Profit Plan Won't Be Ready Until 2024, Yellen Says
October 11, 2023 05:02 AMOECD Reveals Multilateral Treaty For Profit Reallocation Plan