Tag Archives: contemporaneous documentation

SALT Transfer Pricing Quiz
Doug's TP Grab Bag / SALT Transfer Pricing

SALT Transfer Pricing Quiz

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Measure Your SALT & Transfer Pricing Know-How & Win with the 6-Question SALT TP Quiz! Alas, Quiz Prize eligibility closed on April 30, 2022. However, if you haven’t yet read the 2022 Tax Notes State article “SALT Transfer Pricing — What You Need to Know,” there is still time to request a copy of the article from within the Quiz, which we will keep open until 31 May 2022 for this purpose. WTP Advisors is administering the Quiz and all responses (score, name, etc.) will be kept in strict confidence unless, of course, you want us to call and tell your boss how smart you are! Continue reading →

“SALT Transfer Pricing – What You Need to Know: Part 2”
Publications / SALT Transfer Pricing

“SALT Transfer Pricing – What You Need to Know: Part 2”

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This article discusses recent Multistate Tax Commission (MTC) State Intercompany Transactions Advisory Service (SITAS) Committee developments, state application of Tres. Reg. section 482 as evidenced in court cases, state transfer pricing amnesty programs, and measures taxpayers should consider to prepare for state transfer pricing audits. Continue reading →

“SALT Transfer Pricing – What You Need to Know: Part 1”
Publications / SALT Transfer Pricing

“SALT Transfer Pricing – What You Need to Know: Part 1”

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When the subject of transfer pricing arises, most finance and tax professionals think of international transfer pricing. Transfer pricing, however, can play an important role in state and local tax. Part 1 of the article examines: Three major reporting methods available to states under formulary-apportioned corporate tax reporting ◆ The effect of transfer pricing on different reporting methods ◆ The latest Multistate Tax Commission transfer pricing developments. Continue reading →

Six Salaciously SALTy Transfer Pricing Facts You’ll Want to Read More About!
Transfer Pricing

Six Salaciously SALTy Transfer Pricing Facts You’ll Want to Read More About!

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On 24 January 2022, Tax Notes State published SALT Transfer Pricing — What You Need to Know: Part 1. I realize many readers of this blog have an insatiable hunger for all things transfer pricing (with SALT or without). To whet your appetite, here are six salaciously SALTy transfer pricing facts you’ll be longing to read more about in my full coauthored article… Enjoy! Continue reading →

Impactful FYE Transfer Pricing Examination Preparedness Measures
Publications

Impactful FYE Transfer Pricing Examination Preparedness Measures

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U.S.-based MNEs face an inevitable IRS transfer pricing (“TP”) exam sooner rather than later. Fortunately, for U.S. companies in MNE groups, the IRS issued taxpayer guidance on exams in its Transfer Pricing Examination Process, Publication 5300 (TPEP). In this article, we view the TPEP at a high level and provide insights to help tax executives quickly make sense of the IRS’s TP guidance in preparation for 2022 TP documentation and exams in the years ahead. Continue reading →

How WTP Advisors Is Helping Corporate Tax Executives Handle Transfer Pricing Remotely 
Publications

How WTP Advisors Is Helping Corporate Tax Executives Handle Transfer Pricing Remotely 

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I coauthored “How WTP Advisors is Helping Corporate Tax Executives Handle Transfer Pricing Remotely,” which addresses common MNE in-house transfer pricing team pain points and brings a few of my recently developed software solutions to the table (e.g., TP Risk Assessment Model). This article was the concluding article in the September 2020 issue of the bilingual Americas-focused “AMÉRICA, Revista Regional” magazine, which contained articles written by firms in Argentina, Colombia, Costa Rica, Ecuador, and the United States. Continue reading →

Review of and Insights on the IRS Transfer Pricing Examination Process
Exams / Audits / Publications / Transfer Pricing / United States

Review of and Insights on the IRS Transfer Pricing Examination Process

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Attention, international tax managers and transfer pricing professionals: The IRS’s Transfer Pricing Examination Process (TPEP) is your insider’s guide to the IRS’s transfer pricing exams. This comprehensive guide, designed for IRS examiners, openly details the inner workings of their process. Learn how to proactively use this knowledge to strengthen your transfer pricing documentation, anticipate IRS inquiries, and avoid costly adjustments. Don’t be caught unprepared. This in-depth analysis of the TPEP will give you a significant advantage in ensuring your company’s transfer pricing practices meet IRS scrutiny. Discover the key takeaways, practical tips, and strategic insights that can make all the difference in the outcome of your next exam. Continue reading →