United States: Transfer Pricing

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

A&M Tax Policy Quarterly Outlook: Q4 2025

Our Global Tax Policy and Controversy (TPC) Group at A&M Tax is pleased to present the first edition of the A&M Tax Policy Quarterly Outlook (Q4 2025), providing insights for the period from October to December 2025.

United States Tax

AM

Alvarez & Marsal

Are Your Financial Reporting Valuations Compromising Your Tax Positions?

When it comes to completing a company's often extensive financial reporting requirements, it is easy to lose sight of the impact those valuations may have on the company's tax positions.

United States Tax

AC

Ankura Consulting Group LLC

Supplementary Law No. 225/2026: Taxpayers' Defense Code

On January 9, 2026, the final text of the Supplementary Law ("LC") No. 225/2026 was published in the Official Gazette of the Federal Government, which launches the Taxpayers´ Defense Code (the "Code").

United States Tax

MB

Mayer Brown

Recent IRS Guidance On Branch Profits Tax Treaty Benefits For Foreign Reverse Hybrid Entities

The IRS recently issued a Chief Counsel Advice Memorandum (AM 2025-002) that provides helpful guidance regarding the application of the branch profits tax in connection with reverse foreign hybrid entities and U.S. income tax treaties with foreign countries.

United States Tax

FL

Foley & Lardner

The New Pillar Two Framework: Unboxing The Side-By-Side Package

AM

Alvarez & Marsal

A&M Tax Policy Insights – November 2025

AM

Alvarez & Marsal

Transfer Pricing Issues When Dealing With Trusts, Foundations, And Similar Arrangements

United States Tax

N

NERA

EU Tax Directives #6 Repeal Of 3 Proposed EU Tax Directives - New York Office Snippet

United States Tax

LL

Loyens & Loeff

Commentary On New Canadian Transfer Pricing Legislation

United States Tax

RP

Ruchelman PLLC

What Landmark Israeli Transfer Pricing Case, Hexadite Ltd. v. Israel Tax Authority, Means For U.S. Multinationals

United States Tax

RS

Rotfleisch & Samulovitch P.C.

FAQ: How Tax And Tariff Changes Are Impacting Manufacturing CFOs

United States Tax

MG

MGO CPA LLP

U.S. Tax Shifts And Tariff Volatility: What Manufacturing CFOs Need To Know

United States Tax

MG

MGO CPA LLP

U.S. Reporting Requirements For Cross-Border, Related-Party Transactions: What U.S. Taxpayers Must Know Now For Compliance

United States Tax

RS

Rotfleisch & Samulovitch P.C.

A&M Middle East Tax & Customs Newsletter | Fall Edition

AM

Alvarez & Marsal

401(k) And IRA Contribution Limits For 2026: Retirement Savings, Adjustments For Inflation, And SECURE 2.0 Changes American Taxpayers Must Know About

United States Tax

RS

Rotfleisch & Samulovitch P.C.

Back To School 2025: Title IX Updates And How ADR Can Help Universities Resolve Disputes (Podcast)

United States Litigation

J

JAMS

Signed, Sealed, But Not Delivered? Don't Wonder About Taxes Under New Postal Service Rules

United States Tax

N

Nossaman LLP

The Empty Chair At Johannesburg: What It Says About US Power

United States International

SJ

Steptoe LLP

Italy's Rising Tax Evasion Vs The United States' Is Higher, Even With The Voluntary Disclosure Program (VDP)

United States Tax

RS

Rotfleisch & Samulovitch P.C.

Why The IRS Just Made It Easier To Reduce BEAT Exposure On Intercompany Services

The IRS has confirmed that the BEAT SCM exception can apply, even when SCM is not used as the primary transfer pricing method.

United States Tax

MG

MGO CPA LLP

トランプ関税への対応と移転価格への影響

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

United States Tax

JD

Jones Day

Still Fourth Down And Goal For Medtronic Transfer Pricing Case

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

United States Tax

RP

Ruchelman PLLC

Tax Law Changes That Should Trigger Referrals For Your Clients

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.

United States Tax

KR

Kaufman Rossin

How To Align Your Global Supply Chain And International Tax Strategy

United States Tax

MG

MGO CPA LLP

5 Quick Questions For Referrers: How Specialty Tax Adds Value For Your Clients

United States Tax

KR

Kaufman Rossin

Frequently Asked Questions About International Tax And Supply Chain Realignment

United States Tax

MG

MGO CPA LLP

Amendments To The German Regulation On The Attribution Of Profits To Permanent Establishments (Betriebsstättengewinnaufteilungsverordnung) Relating To Insurance Permanent Establishments

United States Tax

AM

Alvarez & Marsal

Eaton's Loss To IRS Sparks Concerns Over EU Privacy Compliance

European Union Privacy

KR

Kaufman Rossin

Navigating Q2 2025: Essential Income Tax Accounting Insights

AM

Alvarez & Marsal

A First Sale Doctrine Checklist: Six Phases For Successful Tariff Reduction

United States International

HS

Harris Sliwoski

Trump Signs Sweeping Tax Bill Into Law, With Major Implications For Corporate Clients Worldwide

United States Tax

CL

Carter Ledyard & Milburn

IRS Workforce Losses Pose Growing Risk To Businesses Amid Tariff-driven Tax Complexity

United States Tax

WR

Wiley Rein

PER-10/PJ/2025, New Procedures For Tax Information Exchange

AM

Alvarez & Marsal

A First Sale Doctrine Checklist: Six Phases For Successful Tariff Reduction

Our recent blog post, The First Sale Doctrine: A Strategic Tool for Reducing Tariffs—But Only If You Do It Right, generated a lot of questions.

United States International

HS

Harris Sliwoski

Trump Signs Sweeping Tax Bill Into Law, With Major Implications For Corporate Clients Worldwide

President Trump has signed into law a comprehensive tax reform package that permanently extends several expiring provisions of the Tax Cuts and Jobs Act (TCJA) and enacts key tax measures central to his 2024 reelection...

United States Tax

CL

Carter Ledyard & Milburn

IRS Workforce Losses Pose Growing Risk To Businesses Amid Tariff-driven Tax Complexity

The Internal Revenue Service (IRS) is facing a steep workforce reduction that threatens its capacity to assist businesses just as many confront growing uncertainty around global trade...

United States Tax

WR

Wiley Rein

PER-10/PJ/2025, New Procedures For Tax Information Exchange

The Directorate General of Taxes (DGT) has issued PER-10/PJ/2025, an implementation regulation of Minister of Finance Regulation No. PMK 39/PMK.03/2017...

AM

Alvarez & Marsal

Section 899: Potential Tax Increases For Canadians Investing In The U.S.

United States Tax

GW

Gowling WLG

Navigating BEAT And Transfer Pricing: Strategies To Minimize U.S. Tax Liability

Companies can reduce BEAT liability by reclassifying payments, capitalizing costs into COGS, or restructuring contracts to limit related-party payments.

United States Tax

MG

MGO CPA LLP

Hooray For New Math: Is It Really A Simplified Transfer Pricing Approach For 2025?

As promised before the end of 2024, Treasury and the I.R.S. outlined their approach to the codification of Amount B, a component of the O.E.C.D. Pillar One approach1 ("O.E.C.D. guidance")...

United States Tax

RP

Ruchelman PLLC

Prix De Transfert : La Détermination Du Taux D'intérêt De Référence Concernant Les Avances Intragroupe

Dans une décision qui sera mentionnée aux tables du Recueil Lebon, le Conseil d'Etat apporte des précisions relatives au régime...

European Union Tax

MB

Mayer Brown

OECD's Amount B: Simplified Transfer Pricing For Routine Marketing And Distribution Activities

On Feb. 19, 2024, the Organization for Economic Cooperation and Development (OECD) amended its transfer pricing guidelines to include "Amount B," a standardized approach...

GT

Greenberg Traurig, LLP

IRS Notices Adoption Of Amount B; Transfer Pricing Penalties Still In Play

United States Tax

CD

Caplin & Drysdale

Your U.S. Market Entry Pre-Arrival Tax Planning Checklist

United States Tax

MG

MGO CPA LLP

Contract Manufacturing: Considerations For Transfer Pricing In France

United States Tax

N

NERA

Thoughts On The Amount B Framework: Considerations For Contributions Within And Beyond The Baseline Scope

United States Tax

N

NERA

IRS Issues Final Rules On Intangible Property Repatriations

United States Tax

MW

McDermott Will & Emery

Essential Guide To Transfer Pricing For Your Multinational Business

United States Tax

MG

MGO CPA LLP

Kilgour V Commissioner Of Taxation [2024] FCA 687: Regrettably On Arm's Length Terms

United States Tax

AM

Alvarez & Marsal

CFOs: Prepare Your Company For IRS Transfer Pricing Audits And Mitigate Risk

United States Tax

MG

MGO CPA LLP

The Aftermath Of Ya Global: Who Is A Partner?

United States Tax

RP

Ruchelman PLLC

Transfer Pricing: Insights For The Alternative Investment Industry

United States Tax

ML

Marcum

Tax Year 2024 Changes, Planning For Businesses To Consider

United States Tax

KR

Kaufman Rossin

So You Think You're In Control: When Do Transfer Pricing Rules Apply?

United States Tax

CD

Caplin & Drysdale

How Intercompany Agreements Can Mitigate Transfer Pricing Risk

United States Tax

MB

Mayer Brown

Proposed Dual Consolidated Loss Rules: More Traps For The Unwary

United States Tax

AM

Alvarez & Marsal

Supreme Court Opens The Doors To Federal Court Challenges To Treasury And IRS Regulations

United States Tax

SJ

Steptoe LLP

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Latest Videos

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The Trouble With Transfer Pricing For Foreign Parents And US Subsidiaries (Video Content)

AF

ArentFox Schiff

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