The Whirlpool case and Subpart F Mark Martin and Thomas Bettge of KPMG in the US describe the Whirlpool case and its implications for Subpart F planning and controversy. By Mark Martin & Thomas Bettge May 03 2022
Recent changes to section 174 of the US Internal Revenue Code Mark Martin and Thomas Bettge of KPMG in the US describe changes to section 174 of the US Internal Revenue Code and what this may mean for entities that provide... By Mark Martin & Thomas Bettge March 14 2022
US: New regulations apply nexus rule restricting eligibility for US foreign tax credits Mark Martin and Thomas Bettge of KPMG in the US discuss certain aspects of recent US Treasury final regulations regarding foreign tax creditability. By Mark Martin & Thomas Bettge February 16 2022
2021: US transfer pricing year in review Mark Martin and Thomas Bettge of KPMG in the US recap and reflect on US transfer pricing developments from 2021. By Mark Martin & Thomas Bettge January 26 2022
Tax certainty: The march goes on Mark Martin and Thomas Bettge of KPMG in the US review recent developments in ‘tax certainty’. By Mark Martin & Thomas Bettge December 16 2021
US: Pillar one’s Amount A – a revolution in TP controversy Mark Martin and Thomas Bettge of KPMG in the US discuss the Amount A tax certainty process and how it turns traditional transfer pricing dispute resolution on its head for... By Mark Martin & Thomas Bettge November 29 2021
What is in store for US TP in the 2021–22 priority guidance plan? Mark Martin and Thomas Bettge of KPMG in the US describe the transfer pricing items in the Treasury-IRS 2021–22 priority guidance plan, and explore how these may change or reinforce... By Mark Martin & Thomas Bettge October 20 2021
Second US trial in Medtronic v. Commissioner may point to unspecified TP method Mark Martin and Thomas Bettge of KPMG in the US discuss the second US Tax Court trial in Medtronic v. Commissioner and consider how the case may ultimately be resolved. By Mark Martin & Thomas Bettge September 24 2021
US: Tax Court finds limits to treaty-based double tax relief Mark Martin and Thomas Bettge of KPMG in the US discuss the US Tax Court’s recent decision in Toulouse v. Commissioner and its ramifications. By Mark Martin & Thomas Bettge September 14 2021
IRS memo raises issues for post-Altera stock-based compensation true-ups Mark Martin and Thomas Bettge of KPMG in the US describe a July 13 2021 IRS advice memorandum and how its conclusions create risks for taxpayers that true-up unshared stock-based... By Mark Martin & Thomas Bettge September 06 2021
