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What does a case about fishing have to do with transfer pricing?
by Lisa Yashar, WTP Advisors ———- In the case Loper Bright Enterprises v. Raimondo, regarding a U.S. law governing marine fisheries management, the Supreme Court overturned the longstanding Chevron Doctrine. Its impact will be wide-reaching, providing opportunities to challenge agency interpretations of laws. This includes the treasury regulations under IRC § 482. What is the…
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Apple, the EU, and Country by Country Reporting
Read more: Apple, the EU, and Country by Country Reportingby Kash Mansori, WTP Advisors Apple, the EU, and Country by Country Reporting The story of Apple Inc. and the European Commission is well known by now. Back in August of 2016 the EU’s Competition Commission announced their ruling that Ireland had given Apple an unfair sweetheart deal allowing it to pay less tax in…
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Master File / Local File Transfer Pricing Documentation FAQs
Read more: Master File / Local File Transfer Pricing Documentation FAQsby Kash Mansori, WTP Advisors Master File / Local File Transfer Pricing Documentation FAQs A client recently asked me to explain the “Master File / Local File” (“MF/LF”) system of transfer pricing documentation that is being adopted by an increasing number of countries. So I thought that there was no time like the present to…
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BEPS Action 13 Update
Read more: BEPS Action 13 Updateby Guy Sanschagrin, WTP Advisors BEPS Action 13 Update Earlier this year, our blog “Master File / Local File Transfer Pricing Documentation FAQs” provided an overview of what a Master File / Local File (MF/LF) system looks like along with practical considerations on implementing and maintaining the MF/LF system. As of today, our blog pops…