Transfer Pricing

Top News

3M Tells 8th Circ. Chevron's End Dooms IRS In $24M Dispute

By Dylan Moroses

Multinational conglomerate 3M said Thursday that the U.S. Supreme Court's striking down of Chevron deference dictates that the Eighth Circuit overturn a U.S. Tax Court decision that supported the IRS' reallocation of $24 million from the company's Brazilian affiliate.

BlackBerry's $17M In R&D Not Taxable, Canada Court Rules

By David Hansen

BlackBerry Ltd. won't pay taxes on $17.1 million in research and development services it procured from its U.S. affiliates because the services don't fit the definition of foreign accrual property income, the Tax Court of Canada ruled.

Amgen Must Face Suit It Misled Investors On $10.7B Tax Bill

By David Hansen

Amgen lost an attempt to escape a potential class action claiming the pharmaceutical giant hid a $10.7 billion tax bill from investors after a New York federal court ruled there was sufficient evidence for the action to proceed.

Transfer Pricing Guru On Assisting States, Combined Filing

By Paul Williams

Ednaldo Silva’s transfer pricing analytics company EdgarStat LLC recently renewed its contract with New Jersey, furthering his decadeslong run of assisting states that aim to curb profit shifting by scrutinizing intercompany transactions. Silva spoke to Law360 about his transfer pricing philosophy and how he envisions combined reporting affecting the field.

OECD Publishes Streamlined Amount B Model Agreement

By Dylan Moroses

The Organization for Economic Cooperation and Development published a model agreement Thursday for a simplified and streamlined approach to the Amount B portion of Pillar One, a transfer pricing plan for certain baseline marketing and distribution activities.

Abbott Seeks $24M Refund Over Transfer Pricing Adjustments

By Kevin Pinner

Healthcare products giant Abbott Laboratories is owed $24.3 million for overpaid taxes after the IRS incorrectly adjusted its intragroup income and payments this year, the company told the U.S. Tax Court in a petition.

Expert Analysis

The Benefits Of Competent Authority In Int'l Tax Disputes

Multinational enterprises seeking relief from double taxation in a changing international tax landscape should consider utilizing the competent authority process, which provides both taxpayers and domestic tax regulators an efficient and effective means of dispute resolution, say David Farhat and Eman Cuyler at Skadden.

Taxpayer Considerations For La. Audit Program Participation

While the Louisiana Department of Revenue's recently announced transfer pricing managed audit program could resolve time-consuming, expensive audits for many taxpayers, companies nevertheless need to consider the attendant risks in participation, say Jaye Calhoun and William Kolarik at Kean Miller.

International Tax Reform's Implications For Transfer Pricing

As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

MORE COVERAGE

September 24, 2024 06:37 PM

Microsoft Fights Mich. Tax Treatment Of Cost Share Payments

September 23, 2024 05:21 PM

IRS Finalizing Pricing Pact Guidance, Official Says

September 20, 2024 05:32 PM

8th Circ. To Hear Args In 3M's $24M Tax Case Next Month

September 19, 2024 12:30 PM

Apple Ruling Prompts EU Lawmakers To Call For Tax Justice

September 19, 2024 01:22 PM

Nine Countries Sign Treaty For OECD Min. Tax On Payments

September 18, 2024 01:46 PM