Mark Martin and Thomas Bettge of KPMG in the US describe changes to section 174 of the US Internal Revenue Code and what this may mean for entities that provide contract research and development services to related parties.
Mark Martin and Thomas Bettge of KPMG in the US discuss the Amount A tax certainty process and how it turns traditional transfer pricing dispute resolution on its head for in-scope taxpayers.
Mark Martin and Thomas Bettge of KPMG in the US describe the transfer pricing items in the Treasury-IRS 2021–22 priority guidance plan, and explore how these may change or reinforce the US transfer pricing environment.
