February 8, 2024 07:00 PM3M Tells 8th Circ. IRS Used Invalid Regs To Allocate Income
By Dylan Moroses
The base erosion and anti-abuse tax has been relatively easy to avoid without significant legal risk, tax professionals told Law360, a result that may prompt lawmakers to consider revising or replacing the provision as other major parts of the Tax Cuts and Jobs Act expire at the end of 2025.
By Anna Scott Farrell
Medical device company Medtronic asked the Eighth Circuit on Friday to overturn a decision rejecting its pricing method for licensing intellectual property to its Puerto Rican affiliate, saying in the long-running case that Medtronic hadn't used the intercompany arrangement to underreport its income.
By David Hansen
The National Association of Manufacturers joined the chorus of business groups supporting 3M, asking the Eighth Circuit to throw out transfer pricing regulations that allow the Internal Revenue Service to reallocate income to U.S. group members even when foreign laws prohibit outbound payments.
By David Hansen
The Eighth Circuit should set aside transfer pricing regulations from the U.S. Treasury Department that reallocated $23 million of income from 3M's Brazilian affiliate to the parent company, three trade associations told the court in amicus briefs.
By Anna Scott Farrell
A tax group representing multinational tech companies urged the Eighth Circuit to overturn a U.S. Tax Court ruling that found 3M Co. owed taxes stemming from an additional $23 million in income reallocated from its Brazilian affiliate, saying the decision wrongly upheld transfer pricing regulations that were improperly enacted.
By Kevin Pinner
The U.S. should try to undermine the OECD's global tax deal by pursuing reforms to corporate tax policy that would maximize the country's attractiveness to international investors and by cutting funding to the organization, the libertarian Cato Institute said Tuesday.
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.
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.
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.
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February 2, 2024 05:00 PMEaton Asks Court To Agree To Block IRS Summons
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January 29, 2024 06:17 PMInt'l Pricing Method Much Faster Than Others, Report Says
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January 26, 2024 01:43 PMBiz Lobby Urges That BEFIT Wait On Stable Global Tax Rules
January 23, 2024 06:21 PMChile Aims To Rework Anti-Avoidance And CFC Rules
January 19, 2024 04:41 PMUN Could Further OECD's Progress In Global Tax Diplomacy
January 16, 2024 06:44 PMUK Businesses Favor Aligning Transfer Pricing With OECD
January 9, 2024 06:34 PMGlobal Min. Tax Expected To Halve Profit Shifting, OECD Says
January 5, 2024 11:46 AMEU Transfer Proposal Risks Double Taxation, Biz Group Says
January 5, 2024 04:01 PMEaton Corp. Need Not Heed IRS Summons, Judge Advises
January 2, 2024 01:50 PMGroup Status Germane To Adjusting Loan Rates, IRS Says
January 1, 2024 08:02 AMFederal Tax Cases To Watch In 2024
January 1, 2024 08:02 AMInternational Tax Policy To Watch In 2024
January 1, 2024 08:02 AMInternational Tax Cases To Watch In 2024
December 15, 2023 07:32 PMTax Court's Medtronic Method Violates Regs, US Tells 8th Circ.
December 14, 2023 07:20 PMTax Officials Express Support For Multilateral Pricing Program
December 11, 2023 12:24 PMStates Should Value Transfer Pricing Studies, Tax Pros Say