
State Transfer Pricing Cases Show Importance of Documentation
Crowe’s Sowmya Varadharajan and Mike Santoro say recent state transfer pricing developments underscore the need to update intercompany agreements and maintain documentation.

Crowe’s Sowmya Varadharajan and Mike Santoro say recent state transfer pricing developments underscore the need to update intercompany agreements and maintain documentation.

The Center on Budget and Policy Priorities’ Chuck Marr advocates for allowing the Tax Cuts and Jobs Act to end, saying Congress should prioritize low- to moderate-income people with the extra revenue.

This week, experts analyzed Loper Bright’s impact on the 3M transfer pricing dispute, factors to consider before suing the IRS over unpaid ERC claims, and more.
Columnist Andrew Leahey says state and federal governments should collaborate to help modernize sales tax systems and ease the burdens on small businesses.
Artificial intelligence is becoming a bigger part of tax practice and policy every day. The Big Four are spending billions of dollars on AI models, and even mid-tier accounting firms seem willing to at least tread into generative AI transformation, albeit slowly.
Joshua Ehrenfeld and Charles Curley joined Foley & Lardner as partners in its innovative technology sector and transactions practice group in Jacksonville, Fla., the firm announced Wednesday.
Brian Organ joined Nixon Peabody as partner in its project finance and public finance practice in San Francisco, the firm announced Tuesday.
James Saeli joined Winston & Strawn as a partner in its transactions department and member of its tax practice in New York, the firm announced Monday.
James Stewart joined Charles Russell Speechlys as a partner in its corporate tax and incentives team in London, the firm announced Monday.
Although over 100 countries have signed the Multilateral Instrument, courts around the world have diverged in their application of the Principal Purpose Test, says Christos A. Theophilou of STI Taxand.
As Global Capability Centres grow in India, navigating through the right setup strategy (direct ownership or Built Operate Transfer) and understanding Indian tax implications is crucial for an MNE’s business structuring and predictability, say Khaitan & Co. practitioners.
The IRS has staked out its position on §246(b) disallowing some of a taxpayer’s FDII and GILTI deductions in GLAM 2024-002, but the statute is poorly drafted and courts will need to weigh in to resolve open issues, say Baker McKenzie practitioners.
Differing approaches to financial segmentation between taxpayers and governments may cause wildly different Amount B returns, or a different conclusion on being in-scope at all, so documentation of reasonable allocation standards is key to avoiding government rebuttals, say Baker McKenzie practitioners.
The adoption of anti-treaty shopping measures like the PPT in Latin American jurisdictions complicates the analysis of whether treaty benefits will continue to be available for holding companies, and the scope of protection for a grandfathered holding structure remains unclear, say KPMG practitioners.
As the IRS has seen more success in transfer pricing enforcement cases, taxpayers should re-evaluate their current transfer pricing documentation and defense strategy and determine whether a proactive approach through the APA or ICAP program could reduce its global transfer pricing exposure, says a Grant Thornton practitioner.
Get the latest legal, regulatory, and enforcement news and analysis, as well as in-depth business and industry covering in the following areas: