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Microsoft’s $28.9 Billion Proposed Transfer Pricing Adjustment

Microsoft’s $28.9 Billion Proposed Transfer Pricing Adjustment

The IRS in Action on Transfer Pricing

On October 11, 2023, Microsoft Corporation (Microsoft) announced that it received a series of Notices of Proposed Adjustment (NOPAs) from the United States Internal Revenue Service (IRS) related to a decade-long transfer pricing tax audit for the tax years…

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United States – Interim Guidance on APA Requests

United States – Interim Guidance on APA Requests

Transfer Pricing in the News

The IRS issued interim guidance providing the Advanced Pricing and Mutual Agreement (APMA) with new processes and criteria for evaluating the suitability of accepting APA requests and offering an optional pre-request process to provide taxpayers with advice before…

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Brazil Enacts Major Changes to Its Transfer Pricing Rules

Brazil Enacts Major Changes to Its Transfer Pricing Rules

Transfer Pricing in the News

Brazil enacted Law No. 14,596 adopting Provisional Measure No. 1,152 in June of 2023. The law inaugurates a significant change in Brazilian transfer pricing rules. Brazil’s transfer pricing rules were more formulaic and not aligned with the arm’s length standard…

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Transfer Pricing in Unexpected Places – REITs

Transfer Pricing in Unexpected Places – REITs

Most people think of transfer pricing as an international issue that only applies to global multinationals. But transfer pricing also comes into play for Real Estate Investment Trusts (REITs), which operate largely in the U.S. Some may not be aware that REITs are subject to a number of transfer…

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Skechers Transfer Pricing Lacked Economic Substance

Skechers Transfer Pricing Lacked Economic Substance

Skechers was found to owe more than $1 million in taxes after losing a transfer pricing dispute that involved a royalty expense taken as a tax deduction for purposes of Wisconsin’s corporate franchise tax. The Wisconsin Tax Appeals Commission ruled in February 2023 that the company did not…

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