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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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What the Focus on “Value Creation” Misses
Read more: What the Focus on “Value Creation” MissesBy Guy Sanschagrin Posted: November 12, 2015 In his blog post: BEPS – What It All Means, my esteemed colleague Kash Mansori explained that a key to a defensible transfer pricing policy is to align the allocation of taxable income among entities in multinational supply chains with “value creation”. And while this concept introduced under BEPS seems sensible in…
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BEPS – What It All Means
Read more: BEPS – What It All MeansBy Kash Mansori Posted: October 29, 2015 It seems that we’ve more or less reached the end of the first chapter of the BEPS saga. Earlier this month the OECD released the final set of BEPS reports, capping off two years of work to remake the world’s ad-hoc system of international corporate taxation. Over the coming…
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The Quantera Global Connection
Read more: The Quantera Global ConnectionBy Kash Mansori, WTP Advisors Posted: September 22, 2015 Earlier this month I had the good fortune to join other members of WTP’s transfer pricing team in Basel, Switzerland, where we participated in the annual meeting of the Quantera Global transfer pricing alliance. WTP is one of two US-based members of the Quantera Global Alliance (the other…