Tax & Accounting Blog

Defending your State Transfer Pricing Position

Defending your State Transfer Pricing Position

State tax authorities have the ability to increase the tax base of your state affiliates if they can assert that your intercompany pricing is inconsistent with the arm’s length principle.  Under section 482 in the Internal Revenue Code, state action may take the form of transfer pricing adjustments, the adding back of related party expenses, … Read More

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OECD Draft Guidelines Expose Deficiency in Intangibles Analyses

The most recent OECD draft guidelines have highlighted a deficiency in the manner in which most Transfer Pricing experts prepare their intangibles analyses; specifically, in the application of the Comparable Uncontrolled Price Method (CUP). By omitting information in their analysis, Transfer Pricing experts are significantly reducing the accuracy of their transfer pricing position. Historically, … Read More

UK House of Commons Committee Pushes For Country by Country Reporting

UK House of Commons Committee Pushes For Country by Country Reporting

The Commons’ International Development Committee recommends country by country reporting by multinationals in a report released August 23, 2012. The report recommends unilateral adoption of country by country reporting and the continued support and encouragement of adoption within the EU of the concept. One focus of the report is the need to promote … Read More

YOUR QUESTIONS ANSWERED #3: SIC CODES AND THE INHERENT RISKS OF CONDUCTING IP ANALYSIS

YOUR QUESTIONS ANSWERED #3: SIC CODES AND THE INHERENT RISKS OF CONDUCTING IP ANALYSIS

For the third week, we’re addressing FAQs from our recent webcast “SIC Codes: Inherent Risks When Conducting IP Analyses.”  So far, we’ve responded to questions that came in from leaders such as licensing filing from the US SEC and why analysts still use SIC codes.  This week, we’d like to share another frequently asked questions on the complex topic of SIC Codes. … Read More

Six IRS Social Media Tools To Help With Your Tax Deadline

Six IRS Social Media Tools To Help With Your Tax Deadline

Look up any subject and literally — chances are there’s an app for that! It is not uncommon now for businesses to grow their presence on the internet via social media. What you may not be aware of is that the Internal Revenue Service (IRS) is also active on numerous social media platforms … Read More