The Supreme Court today decided to hear a case that could have far-reaching implications for US taxation of income earned overseas. The case challenges a […]
Category: News
Turning the Screw: Penalties in Transfer Pricing Disputes
In 2018, the IRS remembered examination teams to carry out a “diligent penalty analysis” in each transfer pricing case. Since then, we’ve observed that the […]
Pillar 1 Amount A Progress Report – Comments Very Much Wanted
At a recent conference, individuals from the US Treasury were very vocal in their desire to receive comments on the Progress Report on Amount A […]
Not So Independent?: The proposed new rules bind the independent appeals office of the IRS
Closed Access a window On September 13, the Treasury proposed new regulations concerning taxpayers’ rights to access the Independent Appeals Office of the IRS (“Appeals”). […]
Get ready for Warp Speed: The new goal to wrap up the APAs is 24-30 months
On 28 September 2022, the OECD released the Bilateral Advance Pricing Arrangement (“BAPA”) Manual. The handbook proposes best practices for jurisdictions to streamline, expedite and […]
GLAM’s analysis of realistic alternatives adopts DCF concepts of business valuation
In November, the IRS Office of Chief Counsel issued a generic legal advice memorandum (“GLAM”) AM-2022-006, entitled “Realistic Alternatives and Tax Considerations in Applying Sections […]
Preparing for the Bad Press (Redux): Tax Transparency Update
As companies prepare for the 2023 SEC filing season, they should also be ready for the inevitable press attention on the effective tax rates of […]
Transfer Parency prices: new FASB proposal
This week, the FASB issued an amendment to a previously proposed update to accounting standards that, if passed, would “increase transparency” in the reporting of […]
New interim APA guidance from the APMA
On April 25, 2023, the IRS’s Advance Pricing and Mutual Agreement (“APMA”) program issued new interim guide for its review of taxpayer Advance Pricing Agreement […]
Mayer Brown joins transfer pricing team
Mayer Brown announced today that Sonal Majmudar, a former international tax consultant at the Internal Revenue Service (IRS), has joined his tax practice as a […]