The Internal Revenue Service (IRS) has released Notice 2025-04 announcing the IRS and US Department of the Treasury’s intention to issue proposed regulations implementing “Amount B,” the OECD’s new method (also known as the...more
The global tax enforcement landscape is progressing rapidly, driven by regulatory changes, increasing cross-border collaboration, and shifts in funding for key tax authorities. Businesses operating in multiple jurisdictions...more
As state revenue agencies train their auditors in traditional IRC §482 transfer-pricing methodologies or outsource transfer-pricing audits to third-party specialists, a recent initiative by the Indiana Department of Revenue...more
The IRS has announced its intention to audit wealthy taxpayers and their associated business entities starting in mid-July. This LawFlash alerts sports owners, athletes, entertainers, and others in these industries to the...more
At a recent American Bar Association Section of Taxation meeting in Washington, DC, Deputy Chief of the IRS Office of Appeals Andrew Keyso, Jr. discussed the extension of a pilot program that provides for the potential...more
A recent policy statement from the US Department of Treasury provides important information for taxpayers navigating US tax reform and alters the existing tax regulatory landscape in a few meaningful ways. Taxpayers should be...more
July 24, 2018, marked a significant, although potentially short-lived, victory for the Internal Revenue Service (IRS), as a panel of the US Court of Appeals for the Ninth Circuit reversed by 2 votes to 1, the full US Tax...more
Serving as a roadmap for how the Internal Revenue Service intends to conduct transfer pricing examinations, the recently released Transfer Pricing Examination Process guide provides a set of processes and practices for the...more