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The Bloomberg BNA International Tax Blog is a forum for practitioners and Bloomberg BNA editors to share ideas, raise issues, and network with colleagues. The ideas presented here are those of individuals, and Bloomberg BNA bears no responsibility for the appropriateness or accuracy of the communications between group members.

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Archive : March 2012

March 23, 2012

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.

March 15, 2012

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.

March 12, 2012

Furthering the Debate over Formulary Apportionment and the Arm's-Length Standard

In his article, “Challenging the Status Quo: The Case for Combined Reporting,” Michael McIntyre, a professor at Wayne State University Law School, makes the case for combined reporting with formulary apportionment.