The Internal Revenue Service (IRS) recently released instructions for employees that may have the effect of deterring some companies from submitting advance pricing agreement (APA) requests. That, in turn, could introduce...more
In episode seven of "GILTI Conscience," hosts Nate Carden and David Farhat talk with Keystone Strategy's Bram Isgur about the issue underlying most major transfer pricing cases: whether to look forward to see what pricing...more