Michael DeSimone

Michael DeSimone works in conjunction with the Tax & Accounting clients of Thomson Reuters in the implementation and use of the ONESOURCE Transfer Pricing products and services. He also assists clients to analyze their business operations and international tax structures. Prior to joining the Tax & Accounting business of Thomson Reuters, Michael has 28 years of Tax experience with various Fortune 500 companies and was most recently the Manager of Tax Research for American Standard Companies Inc. His responsibilities encompassed the analysis and implementation of various strategies involving supply chain management and logistics, commissionaires, IP migration, holding company structures, and multi-jurisdiction financing/credit agreements, transfer pricing studies and documentation, as well as successfully defending these strategies before the IRS and various foreign tax authorities. Michael is an Attorney admitted to practice in New York and New Jersey. He received his JD from New York Law School and his BS, Accounting from Rutgers University.

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Transfer Pricing and Customs Valuations: Will Your Adjustment Be Recognized?

What do you do when you need to make a transfer pricing adjustment, but the goods were delivered to the buyer in a prior tax year?  From a financial reporting and tax return perspective, the company within the local jurisdiction may or may not respect the adjustment.  But is that the end of the issue? … Read More

European Union establishes new commission to monitor tax base erosion efforts

On April 23, 2013, the European Union announced the formation of The Platform of Good Tax Governance.  The Platform is composed of both government and non- government tax experts to keep member states on their toes and up-to-date on the current political momentum to prevent tax base erosion. The Platform is designed to foster discussion … Read More

China and OECD Guidelines– Not So Perfect Together

The China State Administration of Taxation (SAT) recently affirmed in a paper for the United Nations transfer pricing project that they are generally consistent with the OECD guidelines, but that certain modifications may be needed to reflect the particular circumstances existent in China. In particular, the SAT points out three key areas of concern: There … Read More

International Tax Authorities Strike Again

On October 11, 2012, the Federal Administration of Tax Revenues, the AFIP, of Argentina accused a large  agriculture biotechnology company  of using sham loans from related parties to avoid up to $77 million in taxes.  According to the AFIP, the company “pretended” to borrow money from related overseas parties to show lower revenues.  The lenders … Read More

Procurement Transaction Under Fire In Poland

In a recent case, the rational for the use of a same country procurement company was rejected by the auditors and then by the courts in Poland.  The findings that independent forges paid less for steel directly purchased from unrelated mills, than the audited company paid to its related party procurement company, served as the … Read More