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…
New Group Pricing Structure One of my key goals for the 2025–2026 fiscal year…
Corporate Apportionment of Partnership Income A decision issued by the Virginia Court of Appeals, FJ…
The Supreme Court Ruling and the Potential for Tariff Refunds: Their Impact on Transfer Pricing When the United States introduced reciprocal tariffs in April 2025,…
2026 State Tax Changes According to the Tax Foundation, forty-three states made significant changes…
Certainty by Design Tax executives operate in a world where material transactions cannot…
The Price of Regulatory Certainty Prior to the Inflation Reduction Act (IRA) of 2022, transferability…