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The IRS has appealed its loss on in the Tax Court in Medtronic, Inc. v. Commissioner to the Eighth Circuit Court of Appeals.

Last week, the IRS released a mysterious new audit "campaign" that may implicate – inadvertently or otherwise – transfer pricing practices.

Assume the Internal Revenue Service ("IRS") is auditing your company's transfer pricing.

On the morning of 21 July 2026 at a meeting of the Wall Street Tax Association, officials from the Internal Revenue Service (IRS) and Department of Treasury (Treasury) joined in a discussion with income tax...

The IRS has announced a new "Campaign." It will focus its attention on U.S. persons who have reduced their U.S. tax burden by claiming benefits under Puerto Rico Act 22.

More hiring and putting the Covid-19 pandemic in the rear-view mirror are paying off for the IRS unit that handles companies' advance tax deals on intercompany transactions.

The IRS has issued guidance providing for a "simplified and streamlined approach," or SSA, to transfer pricing for marketing and distribution activities that is expressly reliance-eligible for taxable years beginning on or after January 1, 2025.

On February 1, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2011 Revenue Proposals (2011 Green Book), which includes the Obama administration’s plans to significantly reform the U.S. international tax system.

On October 20, 2023, the Internal Revenue Service ("IRS") announced the launch of a three-pronged corporate tax compliance initiative as part of the Inflation Reduction Act of 2022...

In August 2005, the SEC approved proposed changes to NASD Rule 2790 to exclude business development companies, real estate investment trusts and direct participation programsfrom the definition of "new issue" securities offerings.

Under Section 6039(a) of the Internal Revenue Code of 1986, as amended (the "Code"), every corporation that in 2005 issued stock upon the exercise of an incentive stock option (meaning a stock option that qualifies for the favorable tax treatment available under Section 421 of the Code) must furnish to the employee exercising the option, on or before January 31, 2006, a written statement containing certain specified information.

The November 4, 2025, Canadian federal budget introduced new Canadian transfer pricing legislation containing the most consequential change since 1997.

In the evolving world of international transfer pricing, it can be risky to assume that planning strategies to achieve the lowest possible effective tax rates will necessarily be effective—or respected.

In a recently released private letter ruling (PLR 201714028), the IRS Office of Chief Counsel determined that liabilities transferred by a taxpayer to a partnership constituted qualified liabilities...

More formal, rigorous, and perhaps more frequent, state transfer pricing audits appear to be looming on the horizon.

Following the Supreme Court of the United States’ decision invalidating most tariffs imposed under the International Emergency Economic Powers Act of 1977, many companies expect to receive tariff refunds with respect to inventory.

In September, the IRS proposed important changes to the cross-border transfer pricing rules. The proposal not only tailors existing transfer pricing methods to fit the particular shape of ‘service’ transactions better, but also shifts analytical emphasis away from a transaction’s label and onto its economic characteristics