Tax & Accounting Blog

How to Prepare For a Customs Audit in China

How to Prepare For a Customs Audit in China

Customs audits can be a stressful and an expensive process for the import and export operations. Oftentimes, companies are caught by surprise and are unprepared to respond to the many documentation demands from auditors, especially when it involves going back several years on transactions.  This article will explore ways to help you better prepare for … Read More

IRS Currently Accepting Form 8975, Country-by-Country Report

IRS Currently Accepting Form 8975, Country-by-Country Report

On August 11, 2017, the U.S. Internal Revenue Service (IRS) issued Bulletin 2017-2 on its acceptance of Form 8975, Country-by-Country Report. Ultimate parent entities (UPEs) of U.S. multinational enterprise (MNE) groups with $850 million or more of revenues in a previous annual reporting period can now file Read More

UK’s DPT Challenge to Glencore – Can One Defend 80 Percent of the Profits for 20 Percent of the Functions?

UK’s DPT Challenge to Glencore – Can One Defend 80 Percent of the Profits for 20 Percent of the Functions?

Saumyanil Deb and I noted that the UK Diverted Profits Tax should allow taxpayers a chance to defend its intercompany pricing based on a reasonable model of the intercompany transaction in question. In an earlier paper, I posed a simple model of the appropriate gross margin for a sales affiliate, which we applied to the … Read More