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Determining the arm's length transfer price of intercompany transactions has created some of the most resource consuming controversies in taxation and may result in a transfer pricing penalty.

In 2026, the federal tax treatment of export income undergoes a structural shift as FDDEI replaces FDII, eliminating the qualified business asset investment limitation and revising expense allocation rules.

In February 2020, the Organization for Economic Cooperation and Development released Transfer Pricing Guidance on Financial Transactions.

The U.S. and Indian competent authorities are famously at loggerheads over the principles to be applied in transfer-pricing double-tax cases.

NUMBER OF THE WEEK: $80 billion - The total cost of raising the current sequestration caps under a new two-year budget deal released by bipartisan budget negotiators on the evening of Oct. 26.

Shakespeare, through Polonius, tells us "Neither a borrower nor a lender be; for loan oft loses both itself and friend…" Proposed tax rules suggest that it will also soon lose favorable tax treatment.

The Editor interviews Patricia Gimbel Lewis, Member of Caplin & Drysdale, Chartered’s Washington, DC office.

Attached is a memorandum by the National Venture Capital Association that describes a provision in the "mandatory Section 754" provision that could affect private equity funds with respect to transfers of fund interests after October 22, 2004.

Companies can reduce BEAT liability by reclassifying payments, capitalizing costs into COGS, or restructuring contracts to limit related-party payments.

The Directorate General of Taxes (DGT) has issued PER-10/PJ/2025, an implementation regulation of Minister of Finance Regulation No. PMK 39/PMK.03/2017...

The proposed regulations also provide partial relief by providing exempt income and exempt asset treatment with respect to GILTI income.

On July 21, 2023, the Internal Revenue Service ("IRS") released Notice 2023-55 (the "Notice") providing temporary relief from the final foreign tax credit regulations issued in 2022 (the "2022 Final Regulations").

On November 18, 2020, the Tax Court ruled that respondent IRS had not abused its discretion under § 482 when it reallocated more than $9 billion in income for 2007-2009 to petitioner Coca-Cola from its foreign manufacturing affiliates.

On September 16, 2014, the Organization for Economic Cooperation and Development released its 2014 deliverables on the Base Erosion and Profit-Shifting project.

On August 6, 2024, Treasury and the IRS released proposed regulations that address several long-standing issues related to dual consolidated losses (DCLs) and introduce new rules for "disregarded payment losses" (DPLs).

An IRS Office of Chief Counsel memorandum released July 16, 2021 provides a roadmap for IRS transfer pricing examinations involving cost sharing agreements that omit stock-based compensation from the pool of shared IDCs.

On October 11, 2022, the IRS announced draft changes to Schedule UTP, Uncertain Tax Position Statement.1 These are the first material changes to Schedule UTP since the IRS first published...