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News (1667)
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March 20, 2019 Canada Budget Funds Crackdown On Property-Driven Tax Fraud
...Another would be to amend the act so that "transaction" is defined the same way in transfer pricing rules...
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March 19, 2019 IRS Rolling Over On Penalties, Safe Harbors, Ex-Official Says
...The IRS is giving up revenue unnecessarily by failing to assert transfer pricing penalties in audits...
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March 15, 2019 Stock Options Must Be Treated As Real Cost, Ex-IRS Counsel Says
...pricing Kenneth Wood told Law360 in a recent interview....
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March 13, 2019 OECD's Trademark Tax Proposal Raises Treaty Issues, Pros Say
...pricing guidelines, which could be rewritten....
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March 12, 2019 Tax Court Should Use Its Own Experts, Ex-IRS Counsel Says
...The longtime international tax and transfer pricing specialist spoke with Law360 recently about transfer...
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March 08, 2019 Ex-IRS Official Sees Revenue Grab In New Taxing Approaches
...Arguments that traditional arm's-length transfer pricing unfairly deprives some countries of revenue...
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March 08, 2019 Kenneth Wood Looks Back On 3 Decades In International Tax
...Transfer Pricing Penalties How is the IRS applying transfer pricing penalties?...
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March 07, 2019 'Arm's-Length' Not All About Comparables, IRS Official Says
...A comparability analysis is just one of the tools provided in the U.S. transfer pricing regulations to...
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March 06, 2019 Changes To IRS Audit Process Anticipate Foreign Disputes
...New requirements that IRS examiners conducting transfer pricing audits consult with Advance...
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March 06, 2019 Morocco Joins OECD Inclusive Framework
...pricing among units of multinational companies....
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March 05, 2019 OECD Digital Tax Plans Risk Double Taxation, Group Says
...pricing — moreover, such an approach would be harder to apply....
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March 04, 2019 APA Workbook Doesn't Advocate Profit Split Method, IRS Says
...Rather, the model is one "input" for helping determine the best transfer pricing method....
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March 01, 2019 APA Workbook Signals Deference To Profit Split Method
...While technically an arm's-length transfer pricing method, residual profit split, much more than the...
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March 01, 2019 OECD Taps Former Amazon Exec For Top Foreign Tax Position
...Pricing and Financial Transactions Division, the OECD has announced....
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February 22, 2019 Changes In US Tax Law Rattle Treaty Partners, Panelists Say
...pricing disputes....
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February 22, 2019 Arm's-Length Principle Not In Peril, Treasury Official Says
...pricing among the various affiliates in a way that the average rate does not," he said....
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February 22, 2019 Digital Tax Involves Some 'Surrender' Of Revenue, Atty Says
..."In your transfer pricing documentation, if you are going to have to allocate 10 percent of a marketing...
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February 21, 2019 Swiss Mining Co. Glencore Faces $680M UK Tax Assessment
...The company said the amounts relate to "formal transfer pricing, permanent establishment and diverted...