Tax & Accounting Blog

BEPS Blog Series Part 1: BEPS is here… now what?

BEPS Blog Series Part 1: BEPS is here… now what?

Our three-part blog series will offer insights on BEPS compliance and understanding where to start when it comes to country-by-country reporting. For some time, the OECD’s Base Erosion and Profit Shifting (BEPS) guidelines have been a major topic of conversation for multinational enterprises (MNEs) and taxing authorities around the world. With numerous countries moving … 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

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

Evaluating Intercompany Royalty Rates: Why Agree with the IRS Preferred Method?

Evaluating Intercompany Royalty Rates: Why Agree with the IRS Preferred Method?

Imagine a U.S. parent that licenses certain technology to a Canadian affiliate which generates significant profits. While this sounds like good news from a business perspective, the IRS habit of assuming that the royalty should represent all of these residual profits could cause double taxation problems. Interestingly, many economists and the latest from the OECD … Read More

(Closed) SYNERGY 2014 Question of the Week: What do South By Southwest (SXSW) and SYNERGY have in common?

(Closed) SYNERGY 2014 Question of the Week: What do South By Southwest (SXSW) and SYNERGY have in common?

Answer the question at the bottom of this post and you could win a ONESOURCE prize pack!  When you think of “best in breed” conferences, South by Southwest (SXSW) may rise to the top of the list for music, film and interactive.  But what makes this conference in Texas’ state capital such a huge success? … Read More