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In March, the OECD released its discussion drafts in respect of Action 2 and Action 6.

Samsung Electronics has agreed to plead guilty and pay a $300 million fine, the second largest criminal antitrust fine in U.S. history, for participating in a price-fixing conspiracy in the dynamic access random memory (DRAM) industry.

While the IRS does not explicitly mention goodwill or going concern the regulations are intended to sweep in the consideration of any goodwill, including synergy, value that may relate to such transactions.

Discover how artificial intelligence is transforming tax law and intellectual property, while examining critical issues of tax rates and wealth inequality in modern America. Professor Jeremy Bearer-Friend from George Washington University Law School shares expert insights on these evolving challenges in the tax landscape.

Except for the U.S., transfer pricing law frequently includes a provision that references the O.E.C.D. T.P. Guidelines as the guidance that must be used to interpret other provisions of relevant law.

A transfer pricing study or analysis helps companies decide how to price transactions between related parties in different tax jurisdictions.

The Treasury Regulations do not expressly require taxpayers to consider implicit support when pricing intercompany loans.

In this new trade landscape, it is more important than ever to coordinate customs and operational planning with income taxes and transfer pricing.

As artificial intelligence transforms business operations, multinational enterprises face critical questions about where value is created when significant human functions are automated. This analysis examines how the arm's length principle should be applied to controlled transactions involving AI tool development and deployment, with particular focus on risk control functions and the attribution of AI investments across evolving value chains.

With the 9th Circuit Court of Appeal's recent decision in Amazon.com Inc. et al v Commissioner of Internal Revenue, upholding a U.S. Tax Court ruling rejecting a broader definition of intangible assets.

The IRS has released statistics for the 2010 to 2014 tax years relating to Schedule UTP filings, showing that there were 6,320 uncertain tax positions reported in 2014.

Glenn DeSouza, transfer pricing leader in Dentons' Shanghai office, examines China's transfer pricing regime as outlined in three bulletins, the most recent of which was issued in March.

In their latest installment of U.S. Tax Review, co-authors James Fuller, Larissa Neuman and Julia Ushakova-Stein examine recent OECD developments, ...

In today's economic environment, it is no secret that many states face significant budget shortfalls. In response to these circumstances, certain state treasury departments have begun to propose new income tax assessments based on transfer pricing studies that they have "outsourced" to third-party audit firms, often on contingent-fee terms.

The Internal Revenue Service (IRS) continues to publish International Practice Units (IPUs) on transfer pricing.

Multinational enterprises face the complex challenge of allocating entrepreneurial profits from brands among legal entities based on their DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) value contributions. This article presents a solution to measuring the impact of historic DEMPE contributions to a brand's current value, using a case study where DEMPE functions shifted following an acquisition.

While most transfer pricing rules will apply to large multinational enterprise (MNE) groups, family offices, foundations, and trusts cannot ignore them.