A. Tracy Gomes

A. Tracy Gomes

McDermott Will & Emery

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District of Columbia’s Transfer Pricing Enforcement Program and Combined Reporting Regime: Taking Two Bites of the Same Apple

In his recent article, “A Cursory Analysis of the Impact of Combined Reporting in the District”, Dr. Eric Cook claims that the District of Columbia’s (D.C. or the District) newly implemented combined reporting tax regime is...more

4/21/2015 - Combined Reporting Corporate Taxes Tax Revenues Transfer Pricing

Let the Training Begin: MTC Transfer Pricing Audits Draw Near

Deputy Executive Director Greg Matson (a nice guy at heart) announced this week that the Multistate Tax Commission (MTC) has hired its first transfer pricing training consultant and is scheduled to begin training state...more

3/9/2015 - Arm's Length Principle Auditors Audits Corporate Taxes Multistate Tax Commission Training Transfer Pricing

India Shows a Way

Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a...more

2/26/2015 - Corporate Taxes Foreign Investment India International Tax Issues Trade Policy Transfer Pricing

MTC Puts Designs on Increasing State Transfer Pricing Revenues

This past December, the Multistate Tax Commission’s (MTC) transfer pricing advisory committee and its project facilitator Dan Bucks recommended what it calls the “preliminary design” approach for a proposed Arm’s Length...more

2/9/2015 - BEPS Multistate Tax Commission Tax Revenues Transfer Pricing

MTC State Transfer Pricing Program Looms on the Horizon

Transfer pricing is usually considered an international affair, but state governments, like there larger national brethren, have increasingly, and painfully, come to realize that inter-state transfer pricing has become a...more

3/18/2014 - Transfer Pricing Transfer Taxes Transfers

2014 Transfer Pricing Resolutions

Happy New Year! It’s time to make your 2014 transfer pricing resolutions: read a good book, learn a new language and, of course, exercise, exercise, exercise. 2013 was a very active year from a transfer pricing...more

1/8/2014 - BEPS Erosion Intangibles IRS OECD Tax Reform Transfer Pricing

India at the Crossroads

India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more

3/26/2013 - Corporate Taxes Double Taxation Economic Development Foreign Investment India Multinationals Tax Reform Transfer Pricing Vodafone

Russian Transfer Pricing Law

Recently enacted Russian transfer pricing rules now require companies operating in Russia to file annual documentation in compliance with new regulatory guidance regarding related foreign party and certain domestic party...more

2/26/2013 - Advance Pricing Arrangement Program Annual Filings Audits International Tax Issues OECD Penalties Required Documentation Transfer Pricing

Worthless Stock Deductions: Valuation, Transfer Pricing and Technical Considerations

When a multinational enterprise (MNE) has affiliates that have become insolvent, the overall tax planning objective frequently is to secure a U.S. tax deduction (often ordinary) for worthless stock or debt. The essential...more

12/7/2012 - Multinationals Transfer Pricing Valuation Worthless Stock

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