United States: Transfer Pricing

The United States Court of Federal Claims has issued a landmark decision in Alta Wind I Owner Lessor C v. United States, rejecting the use of discounted cash flow methodology for calculating eligible basis in renewable energy tax credits and instead adopting a cost approach based on reproduction costs. This ruling, which concludes a 13-year legal battle over Section 1603 cash grants, establishes that anticipated tax credit values cannot be included in the basis calculation and has immediate implications for

As the global tax controversy landscape evolves and becomes more polarized, marked by cross-border audits and mounting pressure on revenue authorities to collect tax, Jones Day partners examine how geopolitical pressure and rising revenue demands are reshaping tax disputes worldwide. The discussion highlights the complexity of navigating uncertain tax environments where authorities are increasingly sharing information across borders and deploying sophisticated anti-abuse provisions.

U.S. multinationals expanding their European server infrastructure face critical questions about permanent establishment risks. When do data centers and servers create a taxable presence in Europe...

Delaware Statutory Trusts (DSTs) continue to grow in popularity as a passive real estate investment vehicle — especially for investors seeking a streamlined option in a 1031 exchange.

In 2026, the federal tax treatment of export income undergoes a structural shift as FDDEI replaces FDII, eliminating the qualified business asset investment limitation and revising expense allocation rules.

Transfer pricing complexities emerge as artificial intelligence systems increasingly rely on vast training datasets, raising critical questions about how multinational corporations should value and allocate these intangible assets across jurisdictions. The intersection of AI development and international tax law presents novel challenges for determining arm's length pricing when data crosses borders within corporate structures.

The November 4, 2025, Canadian federal budget introduced new Canadian transfer pricing legislation containing the most consequential change since 1997.

The Israeli District Court decision in Hexadite Ltd. v. Israel Tax Authority provides important lessons on transfer pricing, valuation of intangibles, and post-acquisition business-model changes.

OBBBA restores 100% bonus depreciation and R&D expensing — boosting cash flow potential.