Worldwide: Transfer Pricing

In 1992 the Court of Appeals for the Federal Circuit in Nissho Iwai American Corp. v. United States established the First Sale Rule by stating that "sale for export" in the valuation...

The Transfer Pricing (TP) coordination group of the Dutch Tax Authorities (DTA) recently published an internal note, Opzet en aandachtspunten TP‑analyse, explaining how inspectors are expected to prepare...

In 2020, the Government of India (Government) amended its Foreign Direct Investment (FDI) Policy through Press Note 3 (PN3) whereby investments from countries sharing a land border with India...

With the return of 100% bonus depreciation, CFOs can now offset capital investments faster and improve post-tax ROI.

In Canada, taxpayers must file CRA Form T106 to disclose certain non-arm's length transactions with non-residents. The United States does not have a single consolidated disclosure form equivalent to T106.

We are delighted to present the Fall Edition of our A&M Tax & Customs Newsletter. This edition offers timely insights and key analyses of the most significant tax and customs regulatory developments from the past quarter...

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

Federal courts next year are set to decide several cases that could shape how international tax planners will account for uncertainty and enforcement risks in 2025 and beyond.