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…
Intangible Asset Valuation for Tax Purposes Under Fair Market Value and Arm’s-Length Standards Business transactions such as mergers, acquisitions, and business reorganizations often…
The New Corporate Alternative Minimum Tax: Five Not-So-Obvious Rule Applications to Consider Editor’s note: This article was written in mid-December 2022. It…
How Remote Workforce Programs Trigger Myriad Tax Problems—Part One Editor’s note: Given the complexity of this topic, this will…
Embracing ESG: Four Ways Tax Departments Can Add Value Environmental, social, and governance (ESG) considerations command a continually growing…
In Memoriam: Eric Lee Johnson The TEI community recently lost an amazing tax professional and…
TEI Roundtable No. 42: A Deep Dive Into the Murky Waters of UTPs Uncertain tax positions (UTPs) offer taxpayers both opportunities and challenges.…