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The European Commission has repeatedly expressed its ambition to implement the Two-Pillar agreement in a coherent and consistent way across Member States. On December 22, 2021, a mere two days after the Inclusive Framework released its Pillar Two package.

The United States Court of Federal Claims has issued a landmark decision in Alta Wind I Owner Lessor C v. United States, rejecting the use of discounted cash flow methodology for calculating eligible basis in renewable energy tax credits and instead adopting a cost approach based on reproduction costs. This ruling, which concludes a 13-year legal battle over Section 1603 cash grants, establishes that anticipated tax credit values cannot be included in the basis calculation and has immediate implications for

On December 23, 2005, the IRS issued Notice 2006-4 in an apparent attempt to assuage concerns of private companies regarding their compliance with the recent option pricing guidance under Section 409A of the Internal Revenue Code.

In some recent transfer pricing audits, the Internal Revenue Service (IRS) "flipped the tested party" after examining transactions between related U.S. and foreign companies.

As a part of the OECD/G20 project to combat base erosion and profit shifting, the OECD released the first set of reports and recommendations on September 16, 2014.

Transfer pricing is a financial and tax accounting practice that determines the prices at which related entities within a multinational corporation transact with each other for goods, services, or...

Incoming European Commission President Ursula van der Leyen has set out as her primary goal moving forward the mission of further unifying Europe and "protecting the European way of life."

Despite the anticipated tsunami of tax disputes generated by underlying tensions in international taxation, there is reason for hope that appropriate means are being developed to address them efficiently and effectively.

When a Mosotho or a Sesotho speaker says "stay together," they usually mean "live together." By this terminology, the Inclusive Framework of 137 countries that agreed in October...

Many overseas companies reorganize or "flip" to create a US parent company or to access US venture financing and customers.

Transfer pricing is a financial and tax accounting practice that determines the prices at which related entities within a corporate group transact with each other for goods, services, intangibles...

The US Internal Revenue Service (IRS) is auditing a large multinational company. One issue that has emerged is the company's "transfer pricing," the pricing of goods, services, ...

State and local tax (SALT) planning is entering a new phase of complexity. According to the BDO Tax Strategist Survey, over half of all audits and disputes stem from SALT issues. That's no surprise — state rules evolve rapidly...

Just in time for the holidays, the OECD has published detailed guidance about the impact of the COVID-19 pandemic on transfer pricing.

Want to know where specialty tax providers can plug in to help your clients—and where they don't? These frequently asked questions provide clarity for accountants...

Every multinational enterprise has or considers joint ventures (JV), especially in risky activities or locales.

Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles.