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The report from the Joint Committee on Taxation (JCT) on President Obama's 2011 budget, provides revenue estimates for each of the tax provisions in the budget, including proposals about transfer pricing and treatment of intangibles. August 31, 2010
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International Tax Review will present its fifth annual Americas Tax Awards at the Waldorf-Astoria Hotel in New York on September 29 2010. August 25, 2010
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The Large and Mid-Size Business division of the Internal Revenue Service (IRS) will become the Large Business and International (LB&I) division on October 1 in a move that signals a greater focus on transfer pricing. August 24, 2010
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The Canadian mutual agreement procedure (MAP) programme saw an increase in the number of accepted and completed cases in the past year. August 19, 2010
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Russell Young has joined Baker & McKenzie in Chicago as a partner. August 17, 2010
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Tatiana Villani and Anna Cecília Brasil of Machado Associados comment on the main differences between Brazil’s transfer pricing rules and the OECD’s guidelines, and the difficulties and opportunities that this may create for taxpayers. August 17, 2010
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Shiraj Keshvani served until March this year as the chief economist for Canada Revenue Agency’s (CRA’s) competent authority services division and was the national coordinator for the advance pricing arrangement (APA) programme. August 13, 2010
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KPMG has hired two new practitioners with experience of working for the IRS. August 13, 2010
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The US government has decided to reorganise its efforts in international tax administration in an effort to improve compliance. August 06, 2010
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The period of Canada’s Advance Pricing Arrangement (APA) programme that concluded on March 31 2010 saw an all-time high in active cases, but questions about staffing issues still linger. August 04, 2010
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GlaxoSmithKline Canada has won its appeal against a 2008 judgment by the Tax Court of Canada that it paid a Swiss related party too much money for the active ingredient in Zantac. August 02, 2010
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The House Ways and Means Committee’s hearing on transfer pricing issues revealed concern over US corporations’ ability to remain competitive internationally but did not disturb the general consensus around the arm’s-length standard. July 28, 2010
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Cristiane Magalhães and Victoria Rozsavolgyi Bortolin of Machado Associados advise taxpayers in Brazil on when it is best to look for alternative methods to use when establishing transfer prices. July 27, 2010
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A report on transfer pricing from the Joint Committee on Taxation (JCT) in the US has used private company information to outline case studies in a report which concluded that US rules are open to abuse. July 21, 2010
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On June 30 2010 a new decree was published in the Mexican Federal Official Journal, which grants new administrative relief to taxpayers. July 14, 2010
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Holly McClellan, a partner of Baker & McKenzie in Chicago, will join the corporate tax group at General Electric as transfer pricing leader, tax counsel, for treasury and capital markets on August 16. July 09, 2010
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Citrix Systems, a provider of IT solutions, has announced it has settled with the IRS in the range of $12 million to $15 million over disputes about transfer pricing and intellectual property transfers. July 06, 2010
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The Brazilian Congress has passed thin capitalisation rules that will affect the deductibility of interest payments, among other things. July 05, 2010
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Robert Kirschenbaum has moved from Baker & McKenzie to join Miller & Chevalier Chartered in Washington, DC. July 01, 2010
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Cristiane Magalhães and Daniel Orsini Marcondes of Machado Associados Advogados e Consultores explain what the failure of MP 478 to become firm law will mean for taxpayers in Brazil. June 30, 2010
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After 21 years with Ernst & Young, Mike Patton is leaving the firm to join DLA Piper. June 30, 2010
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Canadian law firm Blake Cassels & Graydon has taken two tax litigators from rival McCarthy Tétrault.
June 29, 2010
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Pendo Advisors, a corporate finance and valuation advisory firm in Chicago, has announced the addition of Dan Bourgeois, who has a tax and transfer pricing background, as a managing director June 29, 2010
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Bruce Clements of Kennesaw State University discusses the dangerous area of establishing an economic connection with States in the second of a three-part discussion of state and local considerations in US business planning. June 28, 2010
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Fred O’Riordan, formerly with the CRA, talks about moving into the private sector and reveals his hopes for the future of arbitration between the US and Canada.
June 23, 2010
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The General Tax Bureau (GTB) in Uruguay has extended the deadline for corporate income tax (CIT) payments due after the application of the transfer pricing regime and provided additional guidelines about related parties' status. June 22, 2010
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The Brazilian government has added 14 new jurisdictions to their blacklist of privileged tax regimes. June 16, 2010
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Elen Orsini has left the Brazilian Federal Revenue Service and joined Machado Associados. June 15, 2010
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Alexis Carrera of Ernst & Young in Ecuador explains that the Ecuadorian tax administration seems to be straying further from transfer pricing best practices and the OECD guidelines. June 15, 2010
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The Mexican tax authorities have extended the deadline for companies to submit their 2009 statutory tax reports (dictamen fiscal), though advisers say that transfer pricing documentation still needs to be ready well in advance of the new date. June 11, 2010
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The OECD will review and revise its transfer pricing guidance on intangibles later this year in an effort to clarify one of the most frustrating and notoriously inconsistent areas of international tax. June 10, 2010
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Advisers report consistent attrition at Canada Revenue Agency (CRA) and this along with new initiatives and internal protocols is causing a severe backlog in audits and advance pricing agreement (APA) applications. June 09, 2010
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New transfer pricing rules failed to be passed into law within the Constitutional deadline, creating controversy as to which rule applies to transactions carried out since the beginning of the year. June 07, 2010
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Jennifer Ryan, director of the international tax division at Canada Revenue Agency admits there is “no fairness” in transfer pricing documentation penalties. May 26, 2010
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Brian Trauman has joined KPMG's economic and valuation services practice as a principal and the new East region leader of the transfer pricing controversy services practice. He will be based in New York. May 26, 2010
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Cristiane Magalhães and Henrique Erbolato of Machado Associados Advogados e Consultores in Brazil discuss how the country's complex transfer pricing rules affect cost sharing agreements. May 24, 2010
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Bruce Clements, associate professor of accounting and taxation in the Michael J Coles College of Business at Kennesaw State University and practising CPA delivers the first of a three-part discussion of state and local considerations in US business planning. May 17, 2010
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The Transfer Pricing Practice is the part of the Large and Mid-Size Business (LMSB) division of the Internal Revenue Service (IRS) that is working to "strategically and systematically administer transfer pricing issues". May 14, 2010
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Tax specialists are praising the OECD’s decision to equalise the methods for allocating income and expenses between controlled entities under the arm’s length principle. May 05, 2010
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Two companies that took on the tax authorities in the US and UK over transfer pricing issues, and achieved positive results, have now reported higher than expected earnings. May 04, 2010
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Andréa de Oliveira Ramos and Cristiane Magalhães of Machado Associados in Brazil discuss the important idea of changing fixed profit margins that are used to calculate benchmarks in the country. April 26, 2010
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Hernán Katz of Deloitte in Mexico describes how many transfer pricing difficulties faced by taxpayers in Latin America are linked to the lack of development in the regions’ financial markets. April 26, 2010
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Relying on the March 22 2010 decision in the Xilinx litigation case, Altera Corporation, a leader in reprogrammable logic devices, is confident it will not face the level of corporate tax it was expecting. April 21, 2010
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Todd Miller and Michael Friedman of McMillan in Toronto, Canada explain the documentation rules in Canada and how recent treaty developments and court decision will affect taxpayers. April 20, 2010
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Jennifer Shulman has joined the economic advisory and analysis firm as a vice president in its global transfer pricing practice, based in the US, while Makoto Ikeya was promoted to vice president in the Tokyo office. April 16, 2010
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CRA hires senior manager from Ernst & Young. April 15, 2010
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The deadline for interested parties to submit comments on the new disclosure requirement that would affect many US companies with international dealings has been extended until June 1 2010. April 07, 2010
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Fabia Azevedo and Cristiane Magalhães of Machado Associados in Brazil explain how importers can make use of letters of credit to avoid double taxation where country agreements do not help. March 25, 2010
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After nearly 15 years with Fraser Milner Casgrain, Christopher Steeves has moved to another leading Canadian firm, Fasken Martineau DuMoulin. March 25, 2010
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The US Court of Appeals for the Ninth Circuit has now affirmed the Tax Court's decision in the Xilinx case. March 22, 2010
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Ernst & Young has announced several new partners in the firm's Canadian transfer pricing controversy practice, as well as other senior hires around the world. March 11, 2010
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Purvez Captain and Steven Wrappe of Ernst & Young discuss the advantages and problems that can be found in adding to in-house professionals’ responsibilities. March 08, 2010
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The Brazilian Internal Revenue Service (Brazilian IRS) has published instructions providing the currency appreciation adjustment factor to be used in the calculation of transfer prices for the calendar year 2009. March 03, 2010
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With increased audit activity and recent tax litigation in Canada, determining the arm’s-length pricing of guarantees continues to be a difficult transfer pricing issue and risk for multinationals. Gordon Hands of CUFTanalytics discusses the issues raised in the GE Capital Canada’s guarantee fee transaction litigation. March 01, 2010
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Advisers from Machado Associados summarise the new Brazilian transfer pricing rules and tax deductibility requirements. February 25, 2010
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The Ballentine Barbera Group, a Charles River Associates company that specialises in transfer pricing, has added three new consultants February 18, 2010
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Taxpayers face an additional administrative burden under changes to appendix 9 of the Multiple Information Tax Return (DIM), but the acceptance of electronic filings for certain companies will speed up the process of submitting returns. February 03, 2010
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The Canada Revenue Agency (CRA) has increased the number of cases accepted in its advance pricing agreement (APA) programme, but the average time for closing cases has also risen. January 28, 2010
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Luiz Felipe Ferraz of Demarest e Almeida in Sao Paulo discusses the nuances of Brazilian tax reforms as an important reform was brought in then quickly reversed in late 2009. January 27, 2010
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Whether existing methods of resolving transfer pricing disputes are suitable for use in developing countries was the subject of an interesting panel at the UN expert group meeting on transfer pricing. January 21, 2010
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How the UN transfer pricing manual should tackle documentation requirements was the subject of a spirited panel on the second day of the meeting of experts. January 21, 2010
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Providing adequate education to tax authorities in developing countries is vital when developing transfer pricing systems, according to panellists at the UN group meeting on transfer pricing. January 21, 2010
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Speakers had much to say about the abuse of the tax rules in less sophisticated jurisdictions during a meeting of a UN transfer pricing group meeting this week. January 21, 2010
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Tax professionals from across Africa will meet in Cairo in February to discuss transfer pricing issues affecting the continent. January 20, 2010
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A discussion about country by country reporting caused a heated debate at a meeting at the UN this week January 20, 2010
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In a bid to keep as much money as possible in the local economy as possible, the Ecuadorian government has issued a new reform to tax law, which includes an exemption from the transfer pricing regime for companies that comply with certain conditions. January 20, 2010
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Specialists at a UN meeting have stressed the importance of building transfer pricing units within the tax authorities of developing nations. January 19, 2010
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In a frank discussion at a UN meeting of experts, panellists expressed their frustrations about all the available transfer pricing methods. January 19, 2010
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The first panel of a group meeting on transfer pricing at the UN saw a robust argument over the merits of the formulary apportionment method against the arm’s-length principle. January 19, 2010
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TPWeek will be reporting from the first UN meeting focusing on transfer pricing. January 18, 2010
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Salim Rahim is now a partner in the Washington, DC office of Baker & McKenzie. January 14, 2010
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The international professional services firm announced an 11.4% drop in international revenues, but a 5.3% growth in transfer pricing earnings. January 13, 2010
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In a surprise move the US Court of Appeals for the ninth circuit has withdrawn the opinion and dissent filed on May 27 2009. January 13, 2010
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The application of the transfer pricing rules in Brazil in relation to leasing agreements executed between related parties in Brazil and abroad is a controversial issue. January 12, 2010
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On January 4 2010, the Crown deposited its notice of appeal with the Federal Court of Appeal to the judgment of the Tax Court of Canada issued on December 4 2009 in the case of General Electric Capital Canada Inc v The Queen. January 07, 2010
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A new software product could revolutionise the often lengthy and expensive process of translating transfer pricing documentation. January 07, 2010
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The end of the year brought some good news for US taxpayers struggling with liquidity issues after the tax authorities announced they were extending for another taxable year the liberalised rules that permit a foreign subsidiary to make short-term loans to its US parent. January 07, 2010
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Bankrupt multinational telecommunications equipment manufacturer, Nortel Networks Corporation, has announced that it has entered into a final Canadian Funding and Settlement Agreement that includes the resolution of a transfer pricing dispute with the Internal Revenue Service in the US. January 06, 2010
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John Woodruff joins Gardere Wynne Sewell as a partner in the tax practice group in the Houston office.
January 06, 2010
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Brazil has unveiled legislation that contains the country’s first thin-capitalisation rules. December 18, 2009
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Taxpayers should be pleased with the news that Chile is joining the OECD as the country will benefit from a clearer set of transfer pricing rules, says a leading Chilean tax professional. December 18, 2009
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Paul Flignor, Alan Granwell and Eric Ryan of DLA Piper discuss the landmark Veritas decision and the implications for taxpayers December 18, 2009
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The UN tax committee will discuss drafting guidelines on transfer pricing at a meeting scheduled for January 19 and 20 in New York. December 18, 2009
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Ricardo Escobar, the chief of the Chilean tax authority (Servicio de Impuestos Internos or SII), says the SII has detected “certain abusive behaviours from the Chilean taxpayers”. December 16, 2009
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In a landmark decision, the US Tax Court has addressed the fundamental issues in the valuation of cost-sharing buy-ins and slammed the approach of the Internal Revenue Service (IRS) to the case. December 16, 2009
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Charlene Unitan, formerly with Rolls-Royce and now with boutique firm UNITAX, warns companies to be aware of their tax risks and keep transfer pricing in check. December 16, 2009
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The Uruguayan General Tax Bureau has released a resolution that provides further details on the country’s transfer pricing regime, three months after new regulations were released. December 16, 2009
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Charlene Unitan has set up a transfer pricing boutique called UNITAX. December 15, 2009
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On December 4 2009, the long awaited decision in General Electric Capital Canada Inc v The Queen was released by Canada's Tax Court. December 09, 2009
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A report says that transfer pricing practices in the pharmaceutical industry will become more complex due to the economic and political pressures that companies in the sector are facing December 03, 2009
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Nonconforming transfer pricing rules in some Latin American countries are leading to problems with tax treaty negotiations November 23, 2009
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The UN tax committee will discuss drafting guidelines on transfer pricing at a meeting scheduled for January 2010. November 19, 2009
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The Brazilian government is introducing a new system of reporting imports and exports relating to cross-border transactions involving services and intangibles. November 11, 2009
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Multinational companies need to adjust their transfer pricing systems rapidly to stave off the revenue-hungry tax authorities, says a report. November 11, 2009
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Demet Tepe and Ken Kyriacou of Ernst & Young in Canada explain how companies must be aware of the effect making changes to the business to accommodate climate change initiatives can have on transfer pricing policies. November 09, 2009
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The former managing partner of KPMG's global transfer pricing services practice has established his own firm November 06, 2009
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In its annual report on its mutual agreement procedure (MAP) programme, the Canada Revenue Agency (CRA) notes an increase in both the number of cases brought and also the time taken to resolve the matters. November 04, 2009
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Transfer Pricing Associates signed three more strategic alliance agreements last week, bringing the total of similar link-ups to six during October November 04, 2009
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When considering the current tax legislative agenda, what implications can we expect for transfer pricing? November 04, 2009
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Transfer pricing rules have created unwanted and unforeseen effects in Brazil over the decade they have been in force, presenting certain difficulties to the tax management and control of the operations carried out by multinational companies. October 29, 2009
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Kathrine Kimball, Richard Cooper and Deba Ghosh join the firm as vice presidents. October 22, 2009
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As transfer pricing continues to trouble taxpayers around the world, taxpayers are warned not to cut corners in their documentation when requesting APAs. October 22, 2009
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The commissioner of the IRS, Doug Shulman, has told board directors that they should be paying attention to their tax department's transfer pricing policies October 21, 2009
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The high level of trade conducted through multinational companies in Canada means taxpayers there are subject to intense transfer pricing investigations. October 14, 2009
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The company was given leave to file a reply in answer to the commissioner for Internal Revenue’s response to the petition for a rehearing. October 14, 2009
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The commissioner for Internal Revenue has lodged the IRS’ response to the petition for rehearing in the landmark Xilinx case. October 06, 2009
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Boston firm Caturano and Company has added transfer pricing expertise to the firm’s tax practice. October 05, 2009
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Decree number 392/009 amends and clarifies some of the detailed regulations established by decree number 56/009, which was issued in January 2009. October 05, 2009
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The Venezuelan tax administration (SENIAT) is continuing a transfer pricing audit campaign for fiscal years 2005 to 2008 October 01, 2009
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A recent decision of the Taxpayers Council about the resale price less profit methods described by Brazilian transfer pricing rules has led to debate about the use of such methods for controlling import prices of goods purchased by Brazilian legal entities and packed or repacked locally for resale. October 01, 2009
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At International Tax Review’s fourth annual Americas Tax Awards held in New York on September 30, awards were presented for transfer pricing in 14 countries and cities. There were also a regional award each for Latin America and North America transfer pricing firm of the year. October 01, 2009
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Taxpayers and tax authorities must work together to prevent transfer pricing becoming a barrier to international trade, a leading US Treasury official has said September 24, 2009
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President Barack Obama has revealed Michael Mundaca as his nominee for assistant secretary for tax policy, department of the Treasury. September 17, 2009
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International businesses need to take a more assertive, proactive approach to implementing and managing their transfer pricing policies, a report has said September 09, 2009
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The US tax authorities have unsettled creditors of bankrupt telecommunications equipment provider, Nortel, by submitting a $3 billion claim for back taxes, interest and other penalties September 08, 2009
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The Venezuelan tax authorities have stepped up their attempts to generate extra tax revenue by targeting the transfer pricing methodologies of large automotive and pharmaceutical companies September 02, 2009
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In a series of amicus briefs filed with the US Court of Appeals for the Ninth Circuit, several powerful groups have expressed their support for Xilinx in the latest phase of its battle with the Internal Revenue Service. August 25, 2009
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What modifications to transfer pricing documentation for 2008 can distribution companies consider to reflect the impact of the economic downturn? August 17, 2009
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Xilinx has filed for a rehearing or a hearing en banc in the latest development in this historic case. August 13, 2009
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On September 30, International Tax Review will present its fourth annual Americas Tax Awards in New York, celebrating among other areas, the most innovative transfer-pricing work done in North and South America between August 10 2008 and August 9 2009.
August 12, 2009
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New service regulations from the Internal Revenue Service are not expected to bring a significant effect to transfer pricing in the US. August 12, 2009
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Ward Connolly has left Fenwick & West and joined PricewaterhouseCoopers in San Jose August 12, 2009
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My company is planning to move some operations to Brazil, what are the key transfer pricing considerations in the country? August 11, 2009
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Lucia Fedina, Justen Ghwee, Juliane Keppler, and Gus Lee, of KPMG discuss how the global financial crisis has affected asset management transfer pricing. August 05, 2009
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Fabia Elaine Azevedo and Cristiane Magalhães of Machado Associados discuss the transfer pricing rules on transactions between a Brazilian compnay and a non-resident related party by means of an interposed person August 05, 2009
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Vu Tran and Alexander Gurevich of PricewaterhouseCoopers in the US discuss how the change from US GAAP to IFRS will affect cost sharing arrangements July 01, 2009
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Governments should abandon the arm’s-length price and grant multinationals the discretion to set their own transfer prices internally, says a report from the Rotman School of Management at the University of Toronto. June 24, 2009
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Cristiane Magalhães and Fábio Lima da Cunha of Machado Associados in Brazil report on how the authorities have been using information not accessible to taxpayers to determine arm’s-length prices.
June 15, 2009
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What is the biggest change for companies operating in Mexico following the introduction of the new annual tax return form? June 15, 2009
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The CRA has a reputation for being aggressive. What is the best way to avoid disputes? Or handle them if they arise? June 10, 2009
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Transfer pricing has steadily become one of the number one issues for the Internal Revenue Service (IRS). Alfredo Jay Urquidi of Marsh & McLennan Companies and David Jarczyk of Ceteris discuss. June 09, 2009
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Joe Andrus and Irv Plotkin of PricewaterhouseCoopers explain how President Obama's recent budget may directly affect transfer pricing June 06, 2009
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Speaking of the controversial IRS win in the US Court of Appeals for the Ninth Circuit in the Xilinx case, IRS commissioner Douglas Shulman called the decision a “real victory”. June 04, 2009
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In unprecedented economic times for transfer pricing, some commentators believe that existing transfer pricing models need to change to deal with the situation. May 27, 2009
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The US Internal Revenue Service (IRS) is battling the UK-based pharmaceuticals company GlaxoSmithKline over a potential $1.9 billion in back taxes, interest and penalties. May 27, 2009
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A decision by the Massachusetts Appellate Tax Board (ATB) has sent a warning to state tax auditors not to overreach in assessments related to inter-company pricing of services and products provided between companies and their out-of-state affiliates.
May 14, 2009
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Two cases before the Tax Court of Canada relate to financial transactions meaning taxpayers with intercompany financial transactions should be prepared for greater scrutiny under newly introduced reporting requirements. May 13, 2009
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US President Barack Obama shocked the US corporate tax community this week by announcing a drastic set of plans to change the tax code. But he left transfer pricing alone, for now. May 06, 2009
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Car maker Chrysler is closer to a strategic alliance deal with Fiat SpA after eliminating a transfer pricing hurdle that had threatened the process. April 29, 2009
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Exports made by a Brazilian company to offshore companies controlled by it, carried out in accordance with Brazilian transfer pricing rules, are analysed from a substance over form approach and regarded as sham transactions. April 29, 2009
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While many of the countries across the region claim to have rules that follow the OECD guidelines, experts take a different view. April 22, 2009
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US law firm DLA Piper has expanded its transfer pricing practice with the appointment of three new specialists: two principal economists and one of counsel. April 22, 2009
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The new transfer pricing regulations will bring an increase in audit activity, predicts a senior adviser April 13, 2009
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The US tax authority has established a special transfer pricing council to help coordinate the IRS’ efforts in the area. Barry Shott, [LMSB deputy commissioner (international)], chairs the council and provides more details on the set up and objectives of the group in an exclusive interview with TPWeek. April 13, 2009
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Susan Fickling-Munge and Gerben Weistra have become vice-presidents in Ballentine Barbera/CRA International’s transfer pricing practice April 07, 2009
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The Internal Revenue Service has formed a council to help it deal with transfer pricing matters effectively April 06, 2009
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KPMG adds three to the firm’s economic and valuation services practice April 06, 2009
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It has been discussed whether Brazilian transfer pricing rules apply to the sale of shares and quotas held by Brazilian companies to a related party, as defined by law (including residents in low tax jurisdictions and beneficiaries of privileged tax regimes). April 03, 2009
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After a fall in applications the previous year, more taxpayers filed for advance pricing agreements in 2008 in the US than in any other year in the history of the APA Program April 01, 2009
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John Brown has joined the transfer pricing practice of Ballentine Barbera, an economics consultancy, as a vice president in the New York office March 26, 2009
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As transfer pricing regulations have been changed each year since they were issued in December 2004, Ecuador seemed to be a less than probable candidate to start transfer pricing audits, reveals Alexis Carrera of Ernst & Young March 25, 2009
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Michael Granfield joins the firm as a managing director, bringing decades of experience. March 23, 2009
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The poor state of the economy has led US advance pricing agreement (APA) program officials to become more open to modifying current and prospective APAs. However, no agreements have been changed yet. March 19, 2009
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Under long-anticipated regulations published by the US Internal Revenue Service (IRS), cost sharing arrangements (CSAs) remain an effective tool that multinational taxpayers can use to efficiently develop and manage ownership of valuable intangible property among subsidiaries. But valuations of pre-existing, platform intangibles contributed to CSAs will be scrutinised by the IRS going forward March 12, 2009
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Instructions for completion, guidance formats, and questionnaires related to the review by the registered external auditor (external CPA), and the electronic filing, of the financial audit report for 2008 were published in Mexico’s Federal Register at the end of February. The most relevant (and controversial) aspects of such instructions, formats, and questionnaires have to do with transfer pricing. March 11, 2009
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A desperate budgetary situation could lead the Philippines government to finally introduce transfer pricing guidelines, three years after they were initially proposed. March 11, 2009
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Richard Winston is joining K&L Gates as a partner in its Miami office March 11, 2009
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Robert Green is joining the international tax practice of Skadden Arps Slate Meagher & Flom in Washington, DC March 11, 2009
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A common intercompany transaction between multinational enterprises (MNEs) may result in unforeseen excise tax payments and late filing interest. Matthew Sambrook and Greg Noble of Ernst & Young in Canada explain the dangers. March 09, 2009
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Updated transfer pricing rules released on February 20 place a significant burden on both taxpayers and practitioners, beginning with the calendar year 2008. March 04, 2009
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The cost sharing regulations introduced recently in the US are extremely complicated but offer taxpayers many planning benefits according to one senior transfer pricing adviser. February 25, 2009
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Reliance on on the applicable federal rate (AFR) safe haven of section 1-482.2 of the Internal Revenue Code is not likely to address the need to comply with both US transfer pricing regulations and the expectation of the foreign tax authority that the interest rate on the intercompany loan be consistent with market interest rates for comparable loans February 24, 2009
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According to the explanatory statement of law number 9,430/96, which governs Brazilian transfer pricing rules, the lawmaker is focusing on avoiding tax evasion by means of undercharging exports or overcharging imports from a foreign related party February 17, 2009
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Uruguay has finally introduced guidelines on the application of transfer pricing rules, over two years after the laws were enacted. February 17, 2009
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Diego Etchepare, Juan Carlos Ferreiro and Violeta Maresca, PricewaterhouseCoopers February 11, 2009
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Global economic consulting firm Ceteris has expanded its practice into the Silicon Valley area and hired Mark Madrian as a managing director to lead the Pacific Northwest region February 03, 2009
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On December 31 of each year, Brazilian legal entities must calculate transfer pricing adjustments in order to determine the taxable bases of the corporate income tax (IRPJ) and the social contribution on net profit (CSLL). February 02, 2009
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A recent memorandum of understanding signed by the US and Germany has introduced a set of guidelines that set out how to utilise arbitration in advance pricing agreements. January 28, 2009
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On December 31 2008, the IRS issued new cost sharing regulations in temporary and proposed form. Mark Bronson of Ceteris explains what taxpayers should be doing to comply with the new rules January 20, 2009
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Goldman Sachs’ use of transfer pricing techniques among other issues, has led to investigations in numerous jurisdictions. January 07, 2009
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The Internal Revenue Service has issued the much anticipated regulations on cost-sharing and contract manufacturing arrangements for multinational companies. January 07, 2009
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The burden of keeping up with transfer pricing documentation requirements is becoming one of the biggest challenges for multinational corporations, with some taxpayers having to prepare upwards of 500 transfer pricing reports a year
December 17, 2008
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One of the several controversial aspects of Brazil's transfer pricing legislation is the possibility for taxpayers to take into account the “basket approach” criterion to calculate the parameter price. Henrique de Freitas Munia e Erbolato of Machado Associados explains. December 16, 2008
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The Canada Revenue Agency (CRA) recently released its annual report on advanced pricing agreements (APAs) covering the fiscal period ending March 21 2008. December 10, 2008
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During economic downturns, US-based multinationals may find themselves wanting to repatriate cash from foreign subsidiaries. Under such circumstances, transfer pricing may provide a useful mechanism to achieve this in a tax-efficient manner. Mike Murphy, Albert Liguori and Julie Smith of Alvarez & Marsal Taxand explains how December 03, 2008
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Transfer pricing regulations were introduced in Columbia in 2004, Carlos Mario Lafaurie Escorce and Ricardo Suarez of PricewaterhouseCoopers explain the requirements of the laws. December 02, 2008
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Brazilian transfer pricing rules adopt fixed profit margins in methods applicable to import transactions. Fabia Moreira Azevedo of Machado Associados explains why many are critical of the percentage profits margins allowed under the rules November 18, 2008
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Advisers expect President-elect Obama's administration to put changes to transfer pricing rules high on its list of priorities when he takes office November 11, 2008
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Ceteris, a global economic consulting firm that provides transfer pricing, intellectual property and valuation services has expanded into the Boston area by hiring Jill Weise and Mark Bronson as managing directors, and Kate Sullivan as a director November 04, 2008
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The Internal Revenue Service wants to tighten transfer pricing rules to stop multinational companies with US operations using them illegally to cut their tax bills
November 04, 2008
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An experienced Japanese professional has joined the Texas firm October 28, 2008
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The new tax treaty between Spain and Colombia contains transfer pricing implications. Here Moises Curiel and Diego Gonzalez-Bendiksen of Baker & McKenzie outline the treaty elements. October 22, 2008
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Carlos Eduardo Costa MA Toro and Carlos Eduardo de Biasi of Zilveti Sanden Advogados believe that new rules on requesting a reduction in the presumed profit margin are a step forward for Brazilian transfer pricing October 22, 2008
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Daniel Rybnik of EnterPricing says that taxpayers in Argentina should be aware of the different treatment of transfer pricing policies based on variable and fixed factors October 22, 2008
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Greg Noble and Alfred Zorzi, both partners at Ernst & Young in Canada summarise what the OECD business restructuring draft will mean for Canadian taxpayers October 20, 2008
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Santino Di Libero of Gowling Lafleur Henderson believes the inclusion of mandatory arbitration in the fifth protocol to the Canada-US treaty will help the competent authority process between the two countries October 15, 2008
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Forest Laboratories, a US pharmaceutical company, used transfer pricing methods to channel more than $2 billion through its Irish operation in the last financial year October 14, 2008
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Transfer pricing rules have been in place in certain South America jurisdictions for many years but so far, little action has been taking by either taxpayers or the aurthorities. October 14, 2008
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On September 28 2008 Ecuador's president, Rafael Correa won a referendum on a new constitution that provides significant new powers, including some linked to transfer pricing.
October 08, 2008
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Christopher Steeves of Fraser Milner Casgrain analyses the recent CRA report on the mutual agreement procedure program. October 05, 2008
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Mauricio Hurtado and Fred Barrett of PricewaterhouseCoopers delve into restructuring issues for traditional Maquiladoras in Mexico October 05, 2008
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KPMG has made two transfer pricing appointments in the Americas region and the US September 30, 2008
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One of the key players in the IRS-Glaxo transfer pricing dispute that ended in September 2006 has joined The Brattle Group, a firm of economic, finance and regulation consultants that advises companies, law firms and governments around the world September 25, 2008
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New transfer pricing rules introduced in June have caused an increase in audits in Brazil.
September 12, 2008
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Alexis Carrera Reyes of Ernst & Young reports on how reform to new thin-capitalisation rules can help taxpayers in Ecuador August 28, 2008
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TPWeek.com correspondent, Machado Associados, points out that rules on customs valuation and transfer pricing resemble each other in some ways, but diverge in others August 26, 2008
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Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador August 21, 2008
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The US tax court has ruled in a landmark decision that details of a significant transfer pricing court case will not be made public.
August 13, 2008
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US corporations are using transfer pricing regulations to move profits out of the country to avoid paying federal income tax, said a report from the US Government Accountability Office (GAO).
August 13, 2008
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Tracy Gomes to join the Gardere international tax and transfer pricing practice group July 30, 2008
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TP Week correspondent Machado Associados reports on safe harbour rules in the Brazilian transfer pricing regime June 19, 2008
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PricewaterhouseCoopers Canada outlines the main points in the Glaxo Canada ruling June 19, 2008
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SUNAT issues guidance on filing dates for 2007 tax returns June 19, 2008
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Former big four transfer pricing specialist will managing director based in Chicago June 19, 2008
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CRA loses case to gain access to details on financial transactions June 19, 2008
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Pharmaceuticals company could face massive tax bill
June 12, 2008
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Williams moves over after leading transfer pricing at big-four firm June 11, 2008
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Alexis Carrera Reyes, of Ernst & Young in Quito, reveals key moves being taken in Ecuador to end treaty shopping June 05, 2008
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Speaking of the controversial IRS win in the US Court of Appeals for the Ninth Circuit in the Xilinx case, IRS commissioner Douglas Shulman called the decision a “real victory”. June 04, 2008
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Cristiane Magalhães and Fabíola Costa Girão, of TP Week correspondent Machado Associados, analyse the impact of double tax treaties on transfer pricing policy in Brazil June 04, 2008
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CRA audit focuses on Gildan’s offshore sales and marketing subsidiaries June 02, 2008
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In the second in our series on double tax treaties, Gustavo López-Ameri of Deloitte & Touche in Lima reports on Peru's transfer pricing policy May 30, 2008
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Tax authority announces new structure to change filing requirements May 30, 2008
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Tax authority issues advance notice of key changes May 29, 2008
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Software corporation goes to court next month in the US
May 22, 2008
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TP Week’s Brazil correspondent Machados Associados comments on the debate over the basket method May 21, 2008
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Juan Carlos Ferreiro, of TP Week correspondent PricewaterhouseCoopers in Argentina, comments on the computerisation of transfer pricing information May 15, 2008
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Canadian electronic manufacturing systems business hits tax authority trouble May 08, 2008
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Big-four firm announces key appointments in the US and Latin America April 11, 2008
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New departure from IRS programme is senior transfer pricing figure April 10, 2008
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Catherine Snowdon, in New York, reports that unilateral APAs fell from 42 in 2006 to 26 last year
April 10, 2008
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Presidential candidate pledges to eliminate cross-border tax advantages April 03, 2008
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TP Week correspondent Machado Associados reports on the process for transfer pricing audits in Brazil April 03, 2008
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Top level transfer pricing executive John Breen joins DC law firm March 24, 2008
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TP Week correspondent Machado Associados
outlines the environment for transfer pricing documentation in Brazil March 22, 2008
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PKF Texas appoints Frank Landreneau as director of international tax services March 19, 2008
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International transfer pricing consultancy signs Mexico deal with Ortiz, Sosa, Ysusi March 06, 2008
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Carlos Borba, Gonzalo Lucas and Alejandra Barrancos, of Deloitte in Montevideo, report that transfer pricing law has been introduced but no implementing regulations have been yet published March 06, 2008
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Katherine Pinzón, transfer pricing partner in Caracas for Ernst & Young, describes the Venezuelan government’s approach to transfer pricing documentation March 04, 2008
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Speciality international pharmaceutical company concludes advance pricing agreement for 2006-2010 March 01, 2008
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TP Week correspondent Machados explains why the easiest transfer pricing method is not always the best approach February 29, 2008
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Caribbean state confirms OECD principles in law. Brian Hanney reports on a move to documents rules February 07, 2008
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Jorge Castellon and Ramiro Bravo, of Ernst & Young, say that the lack of TP rules in Mexico can incite controversy February 07, 2008
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Supplied by Jorge E Castellon and Ramiro Bravo, Ernst & Young Mexico February 03, 2008
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After 20 years at Deloitte, Verzi joins growing regional practice January 31, 2008
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Supplied by TP Week correspondent DLA Piper January 31, 2008
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TP Week correspondent Machado Associados reports on a key ruling by the Brazilian tax authorities January 24, 2008
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TP specialists forecast multiple adjustments in the wake of new rules January 19, 2008
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Financial adviser recruits leading TP specialist as managing director January 10, 2008
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Transfer pricing specialist Andrew Kim is one of six associates promoted to partner by law firm Fenwick & West January 03, 2008
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Directors fear IRS will review FIN 48 workpapers December 12, 2007
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Ameriprise Financial, a US financial planning company, announced yesterday that it had changed its TP methodology December 04, 2007
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Key government inquiry identifies significant weaknesses in TP policy November 29, 2007
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In an exclusive article, Todd Miller and Michael Friedman, of McMillan Binch Mendelsohn in Toronto, analyse the transfer pricing implications of the protocol November 22, 2007
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James Gatley, of KPMG in Toronto analyses the recent Hallmark Cards ruling October 30, 2007
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The Canada Revenue Agency (CRA) recently released its 2006 annual report on Canada's advance pricing arrangement (APA) programme. The report covers the fiscal period ended March 31 2006 October 29, 2007
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Transfer pricing audit costs Japanese car company in Venezuala October 22, 2007
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Ed Kroft and Deborah Toaze, of McCarthy Tétrault, explain the Canadian Revenue Agency ‘s focus on TP audits October 12, 2007
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The Brazilian tax authorities introduced the data generator programme of the International Audit Systems - PGD-AUDIN. October 08, 2007
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Rene Fleming and Sandra Goldberg of Deloitte in Ottawa comment on binding arbitration in the long-awaited Canada-US protocol October 08, 2007
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Rosa María Gil and Diego González-Béndiksen of Baker & McKenzie explain how transfer pricing rules have developed in Ecuador since they were introduced more than two years ago October 08, 2007
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Luis Eduardo Ocando, for E&Y in Panama City, comments on new regulations for transfer pricing October 08, 2007
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Moisés Curiel, Carlos Linares and Eduardo Méndez of Baker & McKenzie discuss how transfer pricing policies in Mexico have changed since their introduction October 08, 2007
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Sergio Illanes, Miguel Zamora and Ana Paula Güitrón of Baker & McKenzie summarise the key points of the Chilean transfer pricing regime October 08, 2007
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Alvarez & Marsal Taxand, an affiliate of Alvarez & Marsal (A&M), announced it has recruited two experienced transfer pricing economists. Mike Murphy has joined as a managing director and national practice leader and Laurie Dicker as a managing director and economist. They are based in Washington DC. October 02, 2007
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Sponsored Americas piece by Alan Granwell and Eric Ryan of DLA Piper US September 28, 2007
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Gabriela Villavicencio and Armando Cabrera, of Baker & McKenzie, look how Argentina's transfer pricing rules have developed since their introduction in 1998 September 27, 2007
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Bowen to run US TP practice September 27, 2007
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US investment bank extends its financial advisory practice September 27, 2007
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Simone Dias Musa and Clarissa Machado, of Baker & McKenzie, detail the development of the transfer pricing regime in Brazil and point out its peculiarities September 27, 2007