Tax & Accounting Blog

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

Behind the Scenes: The Best and the Brightest

Behind the Scenes: The Best and the Brightest

Meet Natalie Lampas, campus recruiting and sales supervisor at Thomson Reuters. She joined the company in 2003 and worked as a support representative and sales rep. After learning about recruiting while working in human resources, Natalie moved back to sales, where she is responsible for campus recruiting and managing the sales intern program. She is … 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