IRS proposes new rules for intra-group activities

March 01, 2004

Taxpayers must pay attention to proposals in new transfer pricing regulations, which give the IRS substantial discretion to override the method selected by a taxpayer, argue Ken Wood and David Canale of Ernst & Young

Unlock this article.

The content you are trying to view is exclusive to our subscribers.

To unlock this article:

Take a Free Trial or Login

Topics

Feature Sponsored ITR Magazine March 2004

more across site & bottom lb ros

More from across our site

Italy offers lenders opt-out on windfall tax

The controversial measure is being watered down after criticism from the European Central Bank.

Sam Sholli, September 25, 2023

HMRC boosts requests to foreign tax authorities about UK residents

More than 600 such requests were made in 2022, while HMRC has also bolstered its fraud service, it has been revealed.

Sam Sholli, September 25, 2023

This week in tax: EU court strikes out Belgian tax scheme on state aid grounds

The General Court reverses its position taken four years ago, while the UN discusses tax policy in New York.

Ralph Cunningham, September 22, 2023

Viersen, Germany - January 9. 2022: Closeup of mobile phone with

Amount B remains prominent sticking point in BEPS talks

Discussion on amount B under the first part of the OECD's two-pronged approach to international tax reform is far from over, if the latest consultation is anything go by.

Ralph Cunningham, September 21, 2023

Innovation and flexibility key to pillar two data readiness

Pillar two might be top of mind for many multinational companies, but the huge variations between countries’ readiness means getting ahead of the game now, argues Russell Gammon, chief solutions officer at Tax Systems.

Russell Gammon, September 20, 2023