Internal Revenue Service sign with a traffic signal in the foreground indicating a red light. The IRS’ recent advice memorandum on periodic adjustments suggests that the agency may belatedly start ...

Tax Notes contributing editor Ryan Finley discusses the latest updates in recent transfer pricing cases Eaton and Medtronic II. This transcript has been edited for length and clarity. David D. Stewart ...

This article explores transfer pricing disputes with tax authorities and related disclosures in financial statements. Recent increases in companies’ risk exposure from these controversies have raised ...

Transfer pricing remains a strategic focus for multinational corporations, intricately linked to their global tax strategies and compliance frameworks. As businesses expand across borders, the impact ...

The Transfer Pricing E-Learning Tool aims to build knowledge and skills of personnel in working on transfer pricing in tax administrations. The Tool is being developed by the Fiscal Policy and ...

c) not consist of proceeds from public offerings or loans/debts. In contrast, the proceeds from private placements (the issuance of new shares on a non-pre-emptive rights basis) are allowed as a ...

This article explores how international tax laws and tariff shocks can together demotivate affiliates of a multinational enterprise (MNE) from pursuing operational excellence and continuous ...