Robert Jennings and Elizabeth Sweigart of Verse Consulting, LLC, on the Tax Court's year-end 2009 decision in Veritas v. Comm'r

On this edition, Robert Jennings and Elizabeth Sweigart discuss the December 2009 Tax Court holding in Veritas v. Comm'r. and summarize transfer pricing methods used by the IRS and the taxpayer to advance their arguments. Mr. Jennings and Ms. Sweigart analyze the court's assessment of the arguments...

The Even More Curious Case of Xilinx, Inc. v. Commissioner and the Future of Transfer Pricing

Editor's Note : The Ninth Circuit's revised opinion of March 22, 2010 agrees with the Tax Court's finding that the cost of employee stock options should not be included as a shared cost in a transaction governed by arm's length principles. Previously, the court's decision of May 27...

Tax Law Community Mind Map Clarifies International Tax Landscape

The Mind Maps available below present the complex U.S. transfer pricing rules and the OECD Model Treaty rules on topics of importance and interest to any professional with international dealings in a convenient, illustrated flow chart format. these maps were prepared by Prof. William Byrnes, Associate...

Practical Guide to U.S. Transfer Pricing

The Practical Guide to U.S. Transfer Pricing explains in depth the U.S. transfer pricing rules, and compares them with the OECD Transfer Pricing Guidelines. The publication, authored by experts from some of the most pretigious law and accounting fims: melds essential principles with insights into...

ALERT: More and More Transfer Pricing Enforcement in Store!

by Patricia Gimbel Lewis, John M. Breen, H. David Rosenbloom, Neal M. Kochman Recognizing the inexorable globalization of business and underscoring the high priority that top management places on international tax compliance, the IRS just announced a realignment of its Large and Mid-Size Business (LMSB...

Deal Reached in Western Union – First Data Transfer Pricing Case

On December 15, 2011, Western Union announced that it entered into an agreement with the Internal Revenue Service to settle a long-standing transfer pricing dispute with its former parent company, First Data Corporation. According to documents filed with the Securities Exchange Commission , Western Union...

Deal Reached in Western Union – First Data Transfer Pricing Case

On December 15, 2011, Western Union announced that it entered into an agreement with the Internal Revenue Service to settle a long-standing transfer pricing dispute with its former parent company, First Data Corporation. According to documents filed with the Securities Exchange Commission , Western Union...

Transfer Pricing and Foreign Tax Credit Analysis for Inter-Branch Transactions

by Dale Bond, Elizabeth Sweigart and Alan Fischl * Conventionally, the structuring and pricing of transactions between US taxpayers and their related parties — or transfer pricing — has been considered the realm of large, multinational enterprises with the US Internal Revenue Service ...

IRS Transfer Pricing Audit Roadmap's Potential Impact on U.S. Taxpayers

by Barry Shott, Richard Barrett, Elizabeth Sweigart and Shwetal Shah * Summary. Improved cooperation, collaboration, and transparency continue to be key themes of the message from the Internal Revenue Service ("IRS") for both its own practitioners and the tax community. In another sign of...