Tax & Accounting Blog

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

End-to-End Supply Chain Visibility

End-to-End Supply Chain Visibility

Organizations are continuously expanding their footprint regionally and globally, making the supply chain professional’s life challenging. This continuous change is tied to an organizations desire to explore low cost production centers and reduce overall costs by placing warehouses and assembling units closer to their customers in order to meet the demand of being faster to … 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

Valuing Gilead’s Intangibles in Light of the Altera Aftermath

Valuing Gilead’s Intangibles in Light of the Altera Aftermath

Taxpayers are free to structure their intercompany transactions as they wish if the intercompany pricing is consistent with the arm’s length standard. Any evaluation of a transfer pricing issue depends on what the fundamental question is. In my view, the IRS lost Altera because it was asking the wrong question. In this blog, we will … Read More