transfer pricing

Climate change and the use of natural resources present us all with a major challenge. We all have our part in it and we can all contribute to ensure that we do not live at the expense of future…

The Tax Court issued a nine to eight split decision of six opinions (three in favor and three dissenting) upholding the Service’s 1994 blocked income regulations. Yesterday, February 9, 2023, the Tax…

On Thursday, August 18, 2022, Chief Judge Kathleen Kerrigan of the U.S. Tax Court published her 75-page decision on the Medtronic and I.R.S. controversy (“Medtronic III”).[1] This decision resulted…

William Byrnes, Texas A&M University School of Law* (33-page draft research available on SSRN) Howdy!  Earlier today the General Court of the European Court of Justice (EGC) sided with Starbucks’…

I have received several requests this July 4th holiday in the U.S. about my initial thoughts on the EU Commission's 56-page published (public version from earlier this week) State Aid preliminary…

In regards to the title of this post, the Ways & Means version of international tax reform moves toward a territorial regime of granting an exemption for foreign profits but then derogates from the…

IRS Operational Update: Reorganization and Risk-Based Approach The IRS new Large Business and International (LB&I) risk approach has been implemented in the  form of “campaigns”, focusing on weighing…

In a 207 page opinion the Tax Court ruled March 23, 2017 that the IRS’s adjustment with respect to Amazon.Inc's transfer pricing buy-in payment for an intragroup cost sharing agreement (CSA) is…

To refresh memories, several months ago I posted part 1 of this study on Kluwer's International Tax Blog: Application of TNMM to Starbucks Roasting Operation: Seeking Comparables Through…