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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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New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles
Read more: New Tax Legislation Consequences on U.S. Transfer Pricing and IntangiblesBy Guy Sanschagrin, WTP Advisors New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles The Tax Cuts and Jobs Act of 2017 (the Act) brought sweeping changes to the international tax landscape, including the transfer pricing arena. Intangible property is at the core of many of these changes. The impact of the new provisions…
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Six Time-Tested TPEP Takeaways
Read more: Six Time-Tested TPEP Takeawaysby Guy Sanschagrin and Doug Schwerdt, WTP Advisors While we have periodically written about the Transfer Pricing Examination Process, Publication 5300 (TPEP) and its predecessor, the Transfer Pricing Audit Roadmap, for this blog post we revisited the TPEP to determine how well this IRS guidance and our initial insights on it have withstood the test of time…
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Country by Country Reporting Update
Read more: Country by Country Reporting UpdateBy Kash Mansori, WTP Advisors Posted: June 14, 2016 The trickle of countries incorporating Country-by-Country Reporting (“CBCR”) requirements into their tax codes has grown into a steady stream. In the past month upcoming legislative or administrative provisions pertaining to CBCR were announced in Austria, Belgium, Germany, Sweden, Switzerland, and Bermuda, the European Parliament approved new CBCR legislation governing the…