United States: Transfer Pricing

いわゆるトランプ関税については、7月22日、相互関税のほか、自動車および自動車部品の税率をいずれも15％とする日米政府間の合意が成立し

In an article published in Insights in 2022, the following comment was made regarding two seemingly never-ending transfer pricing battles being conducted...

The One Big Beautiful Bill Act (OBBBA) is the latest sweeping change to the tax code—and one that advisors can't afford to ignore.

In this new trade landscape, it is more important than ever to coordinate customs and operational planning with income taxes and transfer pricing.

Riveron's M&A Tax and Transaction Services experts have observed the latest changes and evolving trends related to US trade and tariff policies and have participated in several discussions on the potential impacts.

The IRS has issued guidance endorsing a muscular approach to the application of "periodic adjustments" provisions. Those provisions authorize IRS adjustments of a taxpayer's pricing for transfers of high-value intangibles, including platform contribution transactions, for taxable years after the year of transfer, based on the actual, realized profitability of those intangibles in those later years

Do the transfer pricing rules apply to your transaction? If you are asking that question because adjusting transfer prices could reduce your tax bill, the answer likely is "yes."

Multinational groups constantly evolve, grow, and consolidate, and operational facts and circumstances always change. Say a growing company decides to expand internationally. It may choose to incorporate new...

On August 6, 2024, Treasury and the IRS released proposed regulations that address several long-standing issues related to dual consolidated losses (DCLs) and introduce new rules for "disregarded payment losses" (DPLs).