APMA set a record for executed advance pricing agreements (APAs), but high processing times and a hefty pending APA inventory continued to challenge APMA in 2023. Our Federal & International Tax Group evaluates trends gleaned...more
Our International Tax Group unpacks recent IRS guidance and public comments that reveal how the agency is changing its advance pricing agreement (APA) procedures. The Large Business and International Division released a...more
Last year’s historic demand with a smaller staff compounded 2021’s challenges for the Advance Pricing and Mutual Agreement Program (APMA). Our International Tax Group delves into this year’s annual report to evaluate trends...more
Our International Tax Group reviews a pair of tax decisions clarifying the IRS’s ability to cancel advance pricing agreements and how the arm’s-length standard applies to high-value intercompany licensing transactions. ...more
Despite adding personnel and making a concerted effort to speed up the advance pricing agreement process, the Advance Pricing and Mutual Agreement Program (APMA) faces challenges with the mounting demand. Our International...more
Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles. - Pillar One: a new taxing right in the digital world - Pillar Two: a global minimum tax...more
Our International Tax Group analyzes the report on the IRS’s Advance Pricing and Mutual Agreement Program and identifies important insights and trends for advance pricing agreements....more
Our International Tax Group examines how the Organisation for Economic Co-operation and Development’s new guidance reiterates the central role of the arm’s-length standard and provides guideposts for taxpayers and tax...more
Our International Tax Group elaborates on the final regulations recently issued by the IRS and Treasury on the base erosion and anti-abuse tax (BEAT)....more
The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you....more
Can a parent take on losses? Or should the subsidiary incur losses due to risks it assumed? Our International Tax Group investigates the nuances of regulations from U.S. and international agencies and offers actions...more
Our International Tax Group analyzes some of the most interesting and significant provisions of the new Treasury and IRS regulations for the base erosion and anti-abuse tax....more