Tax & Accounting Blog

Technology that Ignites Global Business

Technology that Ignites Global Business

This is part one in a series on how corporations do business globally. For a global business to succeed in today’s world, it needs to hone five pillars of engagement, writes Klaus Schwab, founder and executive chairman of the World Economic Forum. Those pillars are corporate governance, corporate philanthropy, corporate social entrepreneurship, global corporate … Read More

Documenting Intercompany Interest Rates: Using Dealscan and Corporate Bond Data

Documenting Intercompany Interest Rates: Using Dealscan and Corporate Bond Data

A recent LinkedIn transfer pricing discussion provided an odd answer to a reasonable question about practitioners’ experiences with Dealscan. An attorney at a Big Four accounting firm wrote: I would be concerned that these reported prices do not fully reflect an arm’s length price because often times these banks will lend at a lower rate … Read More

Eaton, ASAT, and Section 6038A: A Call for Transfer Pricing Documentation

Eaton, ASAT, and Section 6038A: A Call for Transfer Pricing Documentation

Eaton Corp. v. Commissioner is heating up. Not only has the IRS invalidated its APA, but now it is trying to exclude certain evidence from the trial over the transfer pricing. According to a BNA story: “The IRS is seeking to prevent Eaton Corp. from presenting key testimony related to its business operations at a … Read More