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On Taxes, Can Obama Do More Unilaterally?

After months of high-pitched public debate, the White House acted on his own last month to curb corporate tax inversions, as President Obama claimed he the issue was too grave to wait for a...


Mini One Stop Shop Registration Opens Across Europe

On October 1, 2014, EU Member States launched the Value Added Tax (VAT) Mini One Stop Shop (MOSS) online registration portal for cross-border supplies of electronically supplied services (such as...




The OECD’s Seven BEPS Deliverables: A Quick Tour

The OECD Sept. 16 released its first set of deliverables under its Action Plan on Base Erosion and Profit Shifting, a project to rewrite the global tax system in order to curb the kind of tax...


Some Background on the BEPS Items Coming Sept. 16

On Tuesday, Sept. 16, the OECD will deliver to the G-20 work on seven items under its 15-point Action Plan on Base Erosion and Profit Shifting. In anticipation of this release, below is...




Executive Action on Inversions? Not So Fast.

Can President Obama deal with corporate inversions-which occur when a U.S. company merges with a foreign competitor in order to create a parent organization with a tax residency abroad--on his own? ...



What Everyone's Missing About the Inversion Debate

Corporate inversions -- when a U.S. company expatriates by merging with a foreign entity, to plant its tax flag off-shore -- have become a political flash point. Driven by many high-profile...


In A Globalized, Online World, Where Is Home?

Suppose you live in a high-tax state--New Jersey, perhaps--but you decide you're tired of paying taxes there. So you decide you'd rather pay taxes in Florida, where there isn't a state income tax. ...



Another Voice for Formulary Apportionment

The debate over whether and how to fix the international corporate income tax system just added another prominent, Nobel Prize-winning voice. Joseph Stiglitz, the former chief economist for the...


The World's Movement Toward Tax Transparency

In the past few years, there have been countless news stories about aggressive tax strategies and hordes of cash being stashed in off-shore havens. The sheer abundance of the stories might obscure...




The Apple and the Caterpillar

On April 1, Sen. Carl Levin held the latest in a series of hearings examining what he claims are blatant loopholes in the international tax system.   Previous hearings had called executives...




OECD Announces Revised Timeline for BEPS

The Organization for Economic Cooperation and Development will issue three discussion drafts and hold four public consultations before the end of May as the organization ramps up its...



Country-by-Country Reporting on Fast Track at OECD

Country-by-country reporting is the number-one concern for multinational corporations today. The initiative, part of the OECD’s project on base erosion and profit shifting (BEPS), is on a...



IRS Arguments in Altera and OECD 'Special Measures'

A story in the Nov. 14 issue of Transfer Pricing Report on Altera Corp.’s case in U.S. Tax Court goes to the very heart of a question the OECD is considering in its plan to combat base erosion...





Former Treasury Official Critiques OECD White Paper

Former U.S. Treasury Associate International Tax Counsel David Ernick spoke with Bloomberg BNA Transfer Pricing Report's Kevin Bell last month about the OECD's white paper on documentation. Below is...



BEPS: The Six Pressure Areas

With the Organization for Economic Cooperation and Development to present its plan on base erosion and profit shifting one week from today, a review of what's at stake seems in order. Below is a...


The Internship--and Google's Sales Personnel

“The Internship” isn’t exactly a movie that you’d expect to get into complex issues of international tax. But the dopey, crude comedy – in which Owen Wilson and Vince Vaughn play two...


Robert Cole Remembered

Robert Cole, who worked in the field of transfer pricing for many years, died last month at age 81. In addition to improving the field he worked in, Bob also sought to improve Transfer Pricing...


D.C. Transfer Pricing Challenge Moves Toward Trial

The District of Columbia Office of Tax and Revenue scored a significant victory April 23 in a long-running battle to defend its use of a controversial method of transfer pricing. [ BP Products...


Uncertainty in the Financial Services Area

In today’s issue of Transfer Pricing Report, practitioners from Mayer Brown LLP make a case for seeking a financial services advance pricing agreement, pointing to increased uncertainty under...













Safe Harbors Gain Momentum

Safe harbors have become a big part of the transfer pricing debate over the past year. This is not surprising given the ever-greater need for certainty and the growing discomfort—from some sectors...


Is Altera the case the IRS has been waiting for?

As reported in today’s issue of Transfer Pricing Report, two recent U.S. Tax Court petitions filed by Altera Corp. almost certainly represent the IRS’s chosen litigating vehicle for the issue of...


The Perfect Is the Enemy of Timely APA Completions

Almost exactly a year ago, the IRS announced that its Advance Pricing Agreement program would leave the Office of Associate Chief Counsel (International) and merge with the competent authority...



The OECD and the Future of Global Transfer Pricing

Today, the world’s taxing authorities are looking for more revenue from increasingly limited sources. Many developing nations, eager for their fair share of the tax pie, are enacting transfer pricing rules. But what form should those rules take?





June 6 Panel: The Challenges of Transfer Pricing for Management Fees, Guarantees, and Other Intra-Group Financings.

With little in the way of formal guidance from the IRS or the OECD on the issue, expert panelists at the June 6-7 Bloomberg BNA/Baker & McKenzie transfer pricing conference will consider intercompany pricing of management fees, guarantees, and intragroup financing. The discussion will focus on the stringent conditions that multinational companies face in many jurisdictions to deduct certain intercompany service charges and the best practices for minimizing the possibility of double taxation.


Kickoff Panel June 6: The U.S. Tax Agenda and Its Impact on Transfer Pricing

Multinational companies attempting to plan for the future face the unprecedented challenges of a continuing global economic crisis and a constantly changing tax law environment. The pressure for added tax revenues and the perception that the present U.S. system needs reform make long-term planning difficult.