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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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