North America
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires
The hire of Doug Wick expands Baker McKenzie’s state and local tax practice and adds to the firm’s growing ex-IRS expertise
The president’s tariff regime has already caused misery for taxpayers. Losing at the Supreme Court would mean it was all for nothing
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
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Sponsored by Deloitte Transfer Pricing GlobalJobst Wilmanns and Anodri Suchdeve of Deloitte preview ITR’s upcoming transfer pricing change management guide, produced in collaboration with global transfer pricing industry experts from Deloitte.
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US describe a July 13 2021 IRS advice memorandum and how its conclusions create risks for taxpayers that true-up unshared stock-based compensation costs under cost sharing arrangements.
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Sponsored by QCG Transfer Pricing PracticeJesús Aldrin Rojas of QCG Transfer Pricing Practice warns taxpayers to properly comply with the obligations of the transfer pricing regime in Mexico.
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North American Jurisdictions