The U.S. Supreme Court recently denied cert in Altera Corp. v. Commissioner. This podcast addresses the Altera decision’s impact on transfer pricing and deference. This podcast also addresses prior state transfer pricing decisions and strategies to defend... Read More

On June 22, the US Supreme Court denied Altera Corp.’s petition for certiorari seeking review of the US Court of Appeals for the Ninth Circuit’s decision upholding the US Department of the Treasury’s transfer pricing regulation requiring... Read More

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... Read More

by Mary Riley * It is a general maxim that taxpayers want to minimize their tax liability to the greatest extent possible. However, taxpayers who overzealously pursue this aim risk crossing the line separating permissible tax avoidance from impermissible... Read More

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... Read More

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... Read More

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... Read More

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... Read More

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... Read More

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... Read More

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... Read More

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... Read More