Transfer Pricing of Multinational Companies in the Crosshairs
It’s not hard to understand why the IRS pays so much attention to intercompany pricing on transactions between related companies, particularly those involving cross-border transactions. If you could increase your selling price, by say 10 percent, without increasing your costs at all, imagine the impact that would have on your bottom line. The IRS looks at this the same way, but instead of focusing on the bottom line, they look at it from the perspective of increasing multinational companies’ tax liabilities. Under IRC Section 482, the Internal Revenue Service has virtually unlimited authority to reallocate income among related taxpayers if. Read More.
IRS Ramps Up Focus on Transfer Pricing
During the Tax Executives Institute’s 61st Midyear Conference in Washington, D.C. last week, IRS Deputy Commissioner (International) Michael Danilack announced that the IRS will soon name a new director for transfer pricing, and will initiate a new transfer pricing practice in the near future. Danilack also noted that the IRS will bring in more transfer pricing experts. Before the creation of the separate transfer pricing practice, transfer pricing experts were scattered within the IRS. This new division will bring all the transfer pricing experts together to better focus their efforts, and ensure that transfer pricing regarding U.S. entities is performed. Read More.
CB&H Webinar: International Tax Trends and Challenges (11/19/09)
Join CB&H’s international tax specialists for a discussion of current tax trends and challenges facing international businesses. We will review the fundamentals of U.S. transfer pricing in the context of international transactions between affiliates, and the six (6) basic principles of U.S. Transfer Pricing embodied in Section 482 of the Internal Revenue Code. We will also discuss the New Final Regulations issued on July 25, 2009 with respect to the provision or receipt of intercompany goods, services and intangibles.
BTI’s New “International Tax Insight” Takes a Look at Recent International Tax Developments
Baker Tilly International , CB&H’s international accounting and advisory network, recently launched a new quarterly newsletter summarizing recent cross border tax developments of importance. Some highlights from the debut issue of International Tax Insight include the following: