A. Tracy Gomes

A. Tracy Gomes

McDermott Will & Emery

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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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