Transfer Pricing

By Dylan Moroses

An Eighth Circuit judge cast doubt during oral arguments Tuesday on the government's interpretation of regulations the IRS relied on to reallocate almost $24 million of income to 3M from its Brazilian affiliate that was subject to legal restrictions on royalty payments.

By David Hansen

An HM Revenue & Customs official is among four tax professionals BDO LLP has appointed to its offices in the U.K., the firm announced.

By Paul Williams

Microsoft failed to adequately flesh out its arguments that cost-sharing agreement receipts from affiliates should be included in its Michigan apportionment formula as licenses of intellectual property, the state's tax agency argued in asking the Michigan Tax Tribunal to toss the company's case.

By Paul Williams

New Jersey's tax agency issued another request for bids Friday to contract with a transfer pricing specialist to assist with audits and litigation, following the recent renewal of a contract that is set to expire at the end of November.

By Kevin Pinner

Pfizer Inc. is the only company to withhold a country-by-country breakdown of its tax planning in the Senate Finance Committee's probe into how Republicans' 2017 tax package reduced the pharmaceutical industry's U.S. liabilities, according to a letter Chairman Ron Wyden released Thursday.

By David Hansen

The U.S. Supreme Court's ending of the Chevron doctrine calls for overturning a U.S. Tax Court ruling that let the IRS allocate $24 million of income to multinational conglomerate 3M from a Brazilian affiliate, the U.S. Chamber of Commerce told the Eighth Circuit on Wednesday.