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A sophisticated tax planning technique for take-private transactions demonstrates how companies can leverage built-in losses from one subsidiary to offset gains from another, potentially achieving stepped-up tax basis at no incremental cash cost.

On January 20, 2022, the OECD released the latest version of its OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

This week, the FASB issued an amendment to a previously proposed Accounting Standards Update that would

The IRS plans to audit the wealthiest corporate, partnership, and individual taxpayers to achieve some of its main objectives in 2022.

In this edition of Transfer Pricing Times, we present the latest and most relevant transfer pricing issues and developments from around the globe.

On September 29, 2005, the Treasury Department released the much anticipated Proposed Regulations to Section 409A of the Internal Revenue Code (the "Proposed Regulations").

Intellectual property is one of the key drivers of profitability for a multinational company. Because IP is inherently mobile, tax planning for IP routinely involves intercompany licensing...

It is a common arrangement for chapter S corporations, which pass business profits through to the shareholders for tax purposes, to reimburse the shareholders for tax liability associated with corporate profits.

And yet that is precisely the headline from a recent district court decision in the Western District of Washington.

Clark Armitage and Elizabeth Stevens offer insights in Indepth Feature: Transfer Pricing for the May 2023 issue of Financier Worldwide Magazine.

Clark Armitage and Jose Perez examine critical shifts in US international tax policy, including changes to GILTI and FDDEI regimes that fundamentally alter how multinational enterprises structure their operations. The analysis explores how political priorities around economic competitiveness are reshaping enforcement approaches and transfer pricing strategies for companies operating across borders.

In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers' argument that a notice of a tax claim under a tax covenant served on them by the buyer ...

Although there is a great deal of overlap between valuation, financial accounting and transfer pricing, the gulf between standards is most critically seen with respect to intangibles.

The IRS recently announced that it is taking new steps to improve its effectiveness in transfer pricing audits. In a series of speeches, top IRS officials announced the creation of a "Transfer Pricing Practice" within the Large and Mid-Size Business (LMSB) operating division to "strategically and systematically administer transfer pricing issues."

Multinational companies face a new international tax landscape beginning in 2026, driven by significant reforms under the One Big Beautiful Bill Act (OBBBA).

As a result, the Tax Court held that the regulation did not meet the reasoned decision-making standard in the State Farm Supreme Court case.

At a recent conference, individuals from the U.S. Treasury were very explicit in their desire to receive comments on the Progress Report on Amount A of Pillar One, which was released by the OECD on July 11, 2022.