Wednesday, October 22, 2014

Taxpayers Offering to Participate in IRS Transfer Pricing Initiative, IRS Official Says

May 13, 2010 in Daily Tax Report · Leave a Comment 

Taxpayers have been stepping forward to participate in the Internal Revenue Service’s new transfer pricing initiative within the Large and…

Pace of Change in Cross-Border Transparency Initiatives Increasing, IRS Official Says

May 12, 2010 in Daily Tax Report · Leave a Comment 

The pace of change in the new world of increased transparency and information exchange has “accelerated on all fronts,” Internal Revenue Service Deputy Associate Chief Counsel (International) Theodore…

Best Approach for Implicit Support in Transfer Pricing Guarantees Debated by ABA Panelists

May 12, 2010 in Daily Tax Report · Leave a Comment 

U.S. officials and practitioners May 7 debated the proper approach for pricing related-party guarantees, focusing mainly on whether—and to what degree—a company should take into account the implicit support of…

ANALYSIS: HIRE Act Change Suspends Limitations When Taxpayers Fail to Report International Transactions

May 12, 2010 in Daily Tax Report · Leave a Comment 

A recent amendment to Section 6501(c)(8) has the sweeping effect of keeping the statute of limitations open for all issues on a taxpayer’s return if it fails to report international transactions on…

National Association for Business Economics Sets up Transfer Pricing Roundtable; Initial Teleconference Scheduled for June 24

May 4, 2010 in Daily Tax Report · Leave a Comment 

The National Association for Business Economics has established the NABE Transfer Pricing Roundtable networking group to provide…

Recent IRS Moves on Uncertain Tax Positions, Foreign Bank Reporting Seen Having Transfer Pricing Implications

May 4, 2010 in Daily Tax Report · Leave a Comment 

Recent actions by the Internal Revenue Service on uncertain tax positions and by Congress on reporting and disclosure requirements for foreign banks have implications for transfer pricing, KPMG LLP practitioners…

IRS Looking at Buy-In Issue Surrounding Cost-Sharing Arrangements, Official Says

April 23, 2010 in Daily Tax Report · Leave a Comment 

The Internal Revenue Service is “affirmatively looking” at the buy-in issue for cost-sharing arrangements in the transfer pricing context, Large and…

IRS Uncertain Positions Documents Answer Some Questions, Leave Others, Practitioners Say

April 21, 2010 in Daily Tax Report · Leave a Comment 

The draft schedule and instructions that taxpayers would use to report uncertain tax positions, unveiled by the Internal Revenue Service April 19, are administratively helpful and well…

IRS Unveils Draft Schedule, Instructions for Reporting Uncertain Tax Positions

April 20, 2010 in Daily Tax Report · Leave a Comment 

The Internal Revenue Service April 19 unveiled the eagerly awaited draft schedule and instructions that taxpayers would use to report their uncertain tax positions under…

IRS to Extend Audit Time Where Needed in Transfer Pricing Practice Pilot

April 16, 2010 in Daily Tax Report · Leave a Comment 

IRS, in auditing cases under its transfer pricing practice pilot, will extend the time needed to develop the issues where necessary, Deputy Commissioner (International) Michael…

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