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Tariffs and Transfer Pricing: Managing Global Intangible Property in a Dynamic Trade Environment
by Michael Bredahl, WTP Advisors ———- As global trade shifts in response to tariffs being employed as a key tool of economic policy, U.S. multinationals should urgently reassess their legacy transfer pricing strategies, particularly regarding intangible property (IP). The structure and location of IP ownership can either mitigate or exacerbate tariff exposure, fast becoming a…
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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…
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What to Expect When You’re Expecting… An Audit
Read more: What to Expect When You’re Expecting… An AuditBy Kash Mansori, WTP Advisors Posted: April 26, 2016 No one enjoys going through the audit process. Yet the reality is that most medium and large-sized businesses in the US are likely to have their tax positions audited by the IRS sooner or later. And for companies that have international affiliates, that will inevitably entail…