Valuation Transfer Pricing

News & Analysis as of

"New Regulations Address Outbound Transfers and Transfer Pricing"

On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more

Global Tax News - July 2015

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

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

Supply Chain Efficiency: Valuation and Transfer Pricing Considerations

Deriving maximum cost efficiency from the supply chain is a critical operational issue for multinational enterprises (MNEs) in certain regions. As taxation is typically one of a group’s largest costs, supply chain...more

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