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Corporate Taxes Arms Length Transactions Transfer Pricing

Jones Day

JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision

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The Glencore decision is a landmark ruling on the application of Australia's transfer pricing rules governing transactions within multinational groups. These rules seek to ensure that tax is not avoided as a result of...more

McDermott Will & Emery

IRS Announces More LB&I Campaigns!

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The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more

Orrick, Herrington & Sutcliffe LLP

Ninth Circuit Upholds Validity of Cost-Sharing Regulations that Stray from Arm's-Length Standard

On July 24, 2018, in the Altera Corp v. Commissioner decision, the Ninth Circuit overturned a 2015 U.S. Tax Court opinion and upheld the validity of regulations requiring taxpayers to treat stock-based compensation as a cost...more

Jones Day

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

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As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

McDermott Will & Emery

MTC Arm’s-Length Adjustment Service (Part II): “An Expression of Grief, Pity, or Concern”

McDermott Will & Emery on

Executive Summary - ..Multistate Tax Commission (MTC) transfer pricing program moving forward in some fashion; ..Priority includes information sharing among participating states (and possibly their third party...more

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