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…
The Burgeoning Importance of E-Invoicing Although the United States has not yet officially adopted e-invoicing,…
The Presumption of Correctness A common question tax directors ask when considering whether to…
Technical Corrections to the 2021 Final Foreign Tax Credit Regulations As readers are well aware, almost a year ago, on…
TEI Roundtable No. 40 Foreign Tax Credit Regulations For almost four decades, the foreign tax credit regulations have…
Reconnecting at TEI’s Annual Conference I am very excited about TEI’s 77th Annual Conference, as…
Steve Saunders Steve Saunders gained an appreciation of the complexity of tax…