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Multinational enterprises are likely to see increased scrutiny by tax authorities in post COVID-19 years. Tax authorities will focus on reviewing transfer pricing policies and outcomes for historical tax years affected by COVID-19 and try to distinguish between the economic effects of the pandemic versus normal market risk as a result of business success/failure.

Companies looking to prepare for GILTI implications, whether that is to onshore assets to the U.S. or to keep assets abroad, should pay close attention to BEPS Action 13 regulations in structuring their foreign and domestic investments.

The Multi-State Tax Commission has advocated for applying transfer pricing documentation to state taxation. The MTC proposed a plan for state tax adoption of transfer pricing concepts well-traversed in the international tax area.

The Base Erosion and Anti-Abuse Tax operates as a limited-scope alternative minimum tax, applied by adding back taxable income to certain previously deductible payments and many practitioners and industry are looking towards the final regulations.

Revelations such as the "Paradise Papers" and the "Panama Papers" have accelerated the public's desire to crack down on low-tax jurisdictions that are considered tax havens. Here's a look at the 'Paradise Papers,' Apple and the the world of offshore finance.

The OECD released its highly-anticipated guidance on transfer pricing implications resulting from the COVID-19 pandemic. This article provides a brief summary of several key points.

Private equity funds have to analyze their transfer pricing from multiple angles. There are the fund level considerations and there are also portfolio company considerations. Here is an overview of transfer pricing considerations with examples.

The CBP acknowledges that transfer pricing studies and other transfer pricing-related documentation can act as a starting point for pricing used in a customs context. However, simply relying on tax-related documentation is becoming less acceptable.

The Organization for Economic Co-operation and Development (OECD) added guidance on how countries can implement its country-by-country (CbC) reporting program. Taxpayers and tax authorities alike are preparing for the initial filing of the CbCRs.

The transfer pricing rules set forth in the treasury regulations with respect to IRC Sec. 482 have remained relatively unchanged since 1986. Nonetheless, multinational corporations doing business within the US have had to ensure that their transfer pricing strategies are compliant.

Mexican taxpayers are permitted to recognize deductions from related-party transactions only if certain requirements are met. If a taxpayer's transfer pricing is not tied to the Dictamen Fiscal, the SAT is likely to propose adjustments.

March is a critical month for taxpayers who reside in Mexico as they have to comply with tax obligations such as the Annual Tax Return and information related to a company's intercompany transactions conducted with related parties resident abroad.

International tax took center stage last week when the temporary Treasury regulations on tax inversions put an end to the proposed merger between Pfizer and Allergen.

The New Jersey Tax Court’s recent decision on Kraft Foods Global Inc. v. Director, Division of Taxation to disallow interest payment deductions by a Kraft Foods Inc. subsidiary is a signal that transfer pricing in state taxation is gaining momentum.

In September 2016, the U.S. Treasury Department issued Notice 2016-52, thought to be in response to the European Union’s recent move to collect €13 billion of back taxes from Apple, Inc.

This article focuses on a number of actions MNEs can take to adjust their existing transfer pricing, thereby better positioning themselves in 2020 and helping them defend their transfer pricing position for COVID-19 affected years.

The UK voted on June 23, 2016, to exit the European Union. Even though it is not clear if, when or how Article 50of the Lisbon Treaty on European Union will be triggered, the consequences of a potential exit by the UK may be far reaching.

Global business is changing fast. This post examines pressing reforms to international tax and transfer pricing to fit today's interconnected economy.

The Cayman Islands is a member of the OECD's Inclusive Framework on BEPS. The Department for International Tax Cooperation (“DITC”), the Cayman Islands tax authority, published the Country-by-Country Reporting (“CbCR”) regulations.

The need for multinationals to understand how tariffs impact transfer pricing. Proper documentation, such as an advanced pricing agreement, can facilitate an improved tax position and regulatory compliance.