Tax Strategy
Are You Considering an Advance Pricing Agreement?
Companies Need To Conduct Benefit Analysis To Determine If APA Is Best Approach
In 1991 the Internal Revenue Service (IRS) established the Advance Pricing Agreement (APA) program, allowing a taxpayer to request that the IRS, and potentially other countries, prospectively approve its transfer pricing facts, transfer pricing methodology, and arm’s-length range of results. The certainty provided by this prospective approach, combined with the… Read more »


New Developments in Canada’s General Anti-Avoidance Rule Editor’s note. This article was written in early May. In…
Oops! I Did It Again: Practical Implications of Revenue Procedure 2022-39 A fact, well known in the tax community: every tax…
TEI Roundtable No. 43: Separate, Combined, and Worldwide Unitary State Filings One of the most talked-about education sessions at this year’s…
Buying and Selling CFCs Under New Corporate Alternative Minimum Tax Regime As part of the Inflation Reduction Act, Congress enacted a…
AI, ETL Tools Offer Promising Possibilities Artificial intelligence (AI) and extract, transfer, and load (ETL) tools…
David Gillman David Gillman began his tax career at Peat Marwick, the…