United States: Transfer Pricing

Subscribe

Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

Transfer Pricing, MAP, And Fast Track: The Forces Reshaping Tax Controversy

One message stood out during our Tax Symposium 2026 session, Tax controversy: What’s hot and what’s not: The Internal Revenue Service (IRS) is becoming more strategic...

United States Tax

SR

McDermott Will & Schulte

Tax And Customs In The Resources Sector: An Expanding Toolkit For States

African governments are rapidly modernising their approach to tax and customs in the resources sector. Fiscal tools, tighter compliance frameworks and procedural reforms are reshaping investment and operational conditions across the continent.

United States Tax

KL

Herbert Smith Freehills Kramer LLP

I.R.S. Offers New Settlement For Easement Tax Shelters

In May, the I.R.S. announced a settlement offer for partnerships involved in disputes concerning "syndicated conservation easements." The key features of the offer include a 10% penalty for gross valuation misstatement, instead of a 40% penalty, and no upfront payment required.

United States Tax

RP

Ruchelman PLLC

Q.S.B.S. Stacking: Is The Clock Ticking?

At a Washington tax conference on May 20, Treasury Assistant Secretary for Tax Policy Kenneth Kies reportedly signaled that anti-stacking regulations targeting Code §1202 qualified small business stock (“Q.S.B.S.”) are likely forthcoming.

United States Tax

RP

Ruchelman PLLC

The Ghost Of DEMPE Past, Present, And Future

United States Tax

N

NERA

2026 International Tax Reform Guide For CFOs And Tax Directors

United States Tax

MG

MGO CPA LLP

Tax Planning For Carve-Out And Take-Private Transactions: Use Of Selective Section 338 And/or 336 Elections

United States Tax

KM

Katten Muchin Rosenman LLP

Cost Segregation Studies For DST Investments: What Investors Need To Know

United States Tax

MG

MGO CPA LLP

Is Your Export Income Structured For FDDEI In 2026?

United States Tax

MG

MGO CPA LLP

AI Training Data And Transfer Pricing

United States Technology

MB

Mayer Brown

The Tax Treatment Of Tariff Refunds For Inventory

United States Tax

SR

McDermott Will & Schulte

Tax Strategies: Selling Your S Corporation Business

United States Tax

FB

FBT Gibbons

Unlocking Tax Incentives For Your Winery Under OBBBA

United States Tax

MG

MGO CPA LLP

How Your Business Can Stay Ahead Of New State Tax Changes

United States Tax

MG

MGO CPA LLP

Federal Court Vacates $100K H-1B Payment Requirement

United States Immigration

FL

Fennemore

UPC Central Division Revokes Patent Covering Covid-19 Treatment Remdesivir

United States IP

FH

Finnegan, Henderson, Farabow, Garrett & Dunner, LLP

When The Microphone Lives On Your Face: Smart Glasses In The Workplace And The Clinic

United States Employment

DW

Dickinson Wright PLLC

Students May Sue Professors Individually For Sexual Harassment Under Massachusetts Law

United States Employment

FH

Foley Hoag LLP

U.S. Supreme Court Narrows Government-Contractor Defense – What Federal Construction And Infrastructure Contractors Must Know

United States Government

DM

Duane Morris LLP

New International Tax Rules Reshape Planning For 2026

Multinational companies face a new international tax landscape beginning in 2026, driven by significant reforms under the One Big Beautiful Bill Act (OBBBA).

United States Tax

MG

MGO CPA LLP

Proposed Legislation Aims To Outlaw The First Sale Rule

In 1992 the Court of Appeals for the Federal Circuit in Nissho Iwai American Corp. v. United States established the First Sale Rule by stating that "sale for export" in the valuation...

United States Tax

LS

Lowenstein Sandler

DTA TP Working Group Clarifies Approach To Transfer Pricing Risk Analysis

The Transfer Pricing (TP) coordination group of the Dutch Tax Authorities (DTA) recently published an internal note, Opzet en aandachtspunten TP‑analyse, explaining how inspectors are expected to prepare...

United States Tax

AM

Alvarez & Marsal

A&M's Asia–Pacific Private Capital Tax Top 10 – 2025 Q4

In 2020, the Government of India (Government) amended its Foreign Direct Investment (FDI) Policy through Press Note 3 (PN3) whereby investments from countries sharing a land border with India...

AM

Alvarez & Marsal

A&M Tax Policy Quarterly Outlook: Q4 2025

United States Tax

AM

Alvarez & Marsal

Are Your Financial Reporting Valuations Compromising Your Tax Positions?

United States Tax

AC

Ankura Consulting Group LLC

Supplementary Law No. 225/2026: Taxpayers' Defense Code

United States Tax

MB

Mayer Brown

Recent IRS Guidance On Branch Profits Tax Treaty Benefits For Foreign Reverse Hybrid Entities

United States Tax

FL

Foley & Lardner

The New Pillar Two Framework: Unboxing The Side-By-Side Package

AM

Alvarez & Marsal

A&M Tax Policy Insights – November 2025

AM

Alvarez & Marsal

Transfer Pricing Issues When Dealing With Trusts, Foundations, And Similar Arrangements

United States Tax

N

NERA

EU Tax Directives #6 Repeal Of 3 Proposed EU Tax Directives - New York Office Snippet

United States Tax

LL

Loyens & Loeff

Commentary On New Canadian Transfer Pricing Legislation

United States Tax

RP

Ruchelman PLLC

What Landmark Israeli Transfer Pricing Case, Hexadite Ltd. v. Israel Tax Authority, Means For U.S. Multinationals

United States Tax

RS

Rotfleisch & Samulovitch P.C.

Transfer Pricing Issues When Dealing With Trusts, Foundations, And Similar Arrangements

While most transfer pricing rules will apply to large multinational enterprise (MNE) groups, family offices, foundations, and trusts cannot ignore them.

United States Tax

N

NERA

EU Tax Directives #6 Repeal Of 3 Proposed EU Tax Directives - New York Office Snippet

Loyens & Loeff New York regularly posts ‘Snippets' on a range of EU tax and legal topics. Earlier this calendar year, our ‘EU Tax Directives Series' offered practical, concise summaries of key EU tax directives...

United States Tax

LL

Loyens & Loeff

Commentary On New Canadian Transfer Pricing Legislation

The November 4, 2025, Canadian federal budget introduced new Canadian transfer pricing legislation containing the most consequential change since 1997.

United States Tax

RP

Ruchelman PLLC

What Landmark Israeli Transfer Pricing Case, Hexadite Ltd. v. Israel Tax Authority, Means For U.S. Multinationals

The Israeli District Court decision in Hexadite Ltd. v. Israel Tax Authority provides important lessons on transfer pricing, valuation of intangibles, and post-acquisition business-model changes.

United States Tax

RS

Rotfleisch & Samulovitch P.C.

FAQ: How Tax And Tariff Changes Are Impacting Manufacturing CFOs

United States Tax

MG

MGO CPA LLP

トランプ関税への対応と移転価格への影響

いわゆるトランプ関税については、7月22日、相互関税のほか、自動車および自動車部品の税率をいずれも15％とする日米政府間の合意が成立し

United States Tax

JD

Jones Day

Still Fourth Down And Goal For Medtronic Transfer Pricing Case

In an article published in Insights in 2022, the following comment was made regarding two seemingly never-ending transfer pricing battles being conducted...

United States Tax

RP

Ruchelman PLLC

Tax Law Changes That Should Trigger Referrals For Your Clients

The One Big Beautiful Bill Act (OBBBA) is the latest sweeping change to the tax code—and one that advisors can't afford to ignore.

United States Tax

KR

Kaufman Rossin

How To Align Your Global Supply Chain And International Tax Strategy

Aligning international tax strategy with global supply chain planning helps reduce tax exposure, capture incentives, and increase operational agility.

United States Tax

MG

MGO CPA LLP

5 Quick Questions For Referrers: How Specialty Tax Adds Value For Your Clients

United States Tax

KR

Kaufman Rossin

Frequently Asked Questions About International Tax And Supply Chain Realignment

United States Tax

MG

MGO CPA LLP

Amendments To The German Regulation On The Attribution Of Profits To Permanent Establishments (Betriebsstättengewinnaufteilungsverordnung) Relating To Insurance Permanent Establishments

United States Tax

AM

Alvarez & Marsal

Eaton's Loss To IRS Sparks Concerns Over EU Privacy Compliance

European Union Privacy

KR

Kaufman Rossin

Navigating Q2 2025: Essential Income Tax Accounting Insights

AM

Alvarez & Marsal

A First Sale Doctrine Checklist: Six Phases For Successful Tariff Reduction

United States International

HS

Harris Sliwoski

Trump Signs Sweeping Tax Bill Into Law, With Major Implications For Corporate Clients Worldwide

United States Tax

CL

Carter Ledyard & Milburn

IRS Workforce Losses Pose Growing Risk To Businesses Amid Tariff-driven Tax Complexity

United States Tax

WR

Wiley Rein

PER-10/PJ/2025, New Procedures For Tax Information Exchange

AM

Alvarez & Marsal

Section 899: Potential Tax Increases For Canadians Investing In The U.S.

United States Tax

GW

Gowling WLG

Navigating Tariffs And Income Taxes And Transfer Pricing

United States Tax

JD

Jones Day

Trade, Tariffs, And Tax Effects: Deal-Maker Considerations For Diligence And Structuring

United States International

R

Riveron

IRS Transfer Pricing Guidance: Adjustments Based On Actual Results

United States Tax

CD

Caplin & Drysdale

Three International Tax Cases Practitioners Must Watch In 2025

United States Tax

KR

Kaufman Rossin

Navigating BEAT And Transfer Pricing: Strategies To Minimize U.S. Tax Liability

United States Tax

MG

MGO CPA LLP

See more

Latest Videos

See more

The Trouble With Transfer Pricing For Foreign Parents And US Subsidiaries (Video Content)

AF

ArentFox Schiff

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More