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News (1658)
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June 05, 2015 IRS To Eliminate Large Business Continuous Audit Program
...pricing in the division; and Diana Wollman, former LB&I director of international strategy....
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May 28, 2015 OECD Launches Work On BEPS Treaty Modification Tool
...It also contained draft rules on tax treaty abuse, transfer pricing of intangibles, transfer pricing...
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May 08, 2015 IRS Committed To Arm's Length Standard Despite BEPS
...It also contained draft rules on tax treaty abuse, transfer pricing of intangibles, transfer pricing...
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April 30, 2015 The Laterals Audit: This Month's Tax Attorney Moves
...Baker & McKenzie LLP snagged Barbara Mantegani, a former transfer pricing lead at Grant Thornton LLP,...
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April 29, 2015 OECD Seeks Input On BEPS Cost Contribution Arrangements
...pricing of intangibles under CCAs with the general guidance on the transfer pricing of intangibles found...
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April 24, 2015 Quinn Emanuel's Role In Audit Is Too Large, Microsoft Says
...s transfer pricing activities is allowing the firm a larger role than the government is letting on, the...
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April 14, 2015 IRS Defends Contract With Outside Attys In Microsoft Case
...s transfer pricing practices is fully supported by the law....
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April 14, 2015 Some CSA Receipts Are Income For California Tax Purposes
...Amazon is bitterly locked in a $1.5 billion transfer pricing dispute with the Internal Revenue Service...
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March 31, 2015 McDermott Lures Tax Controversy Trio From Dentons
...pricing, and domestic and international tax planning, McDermott noted....
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March 27, 2015 4 Tips For Negotiating IRS Advance Pricing Agreements
..."A lot of the strategic thought occurs in the decision to pursue an APA or resolve a transfer pricing...
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March 27, 2015 BMC Software May Be Good News For Taxpayers
...BMC eventually agreed to transfer pricing adjustments....
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March 24, 2015 Avoiding Tax Inefficiencies In M&A Integration
...pricing (i.e., the economic allocation of income and expenses in tax jurisdictions that are more favorable...
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March 23, 2015 5 Tips For Companies Navigating BEPS Changes
...Companies will also need to prepare a so-called master file providing an overview of its transfer-pricing...
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March 16, 2015 Switzerland Progresses On OECD Tax Info Exchange
...It also contained draft rules on tax treaty abuse, transfer pricing of intangibles, transfer pricing...
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March 16, 2015 5th Circ. Erases Software Company's $13 Million Tax Debt
...In 2007, BMC signed a transfer pricing closing agreement with the IRS, assenting to an adjustment that...