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
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
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
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
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
Transfer Pricing NEWS The Transfer Pricing Operations (TPO) of the Large Business and International (LB&I) division of IRS released the 26-page Transfer Pricing Audit Roadmap to the public on February 14, 2014. The Transfer Pricing Audit Roadmap (“Roadmap”) provides audit procedures around an approximate 24-month audit timeline. The stated goals of the roadmap are to assist both … Continue reading
TRANSFER PRICING INSIGHTS 