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
Finding consensus: BEPS 2.0 and tax certainty Mark Martin and Thomas Bettge of KPMG in the US examine the Inclusive Framework’s July statement on pillars one and two and consider what it has to say about dispute... By Mark Martin & Thomas Bettge July 28 2021
US: Approach to TP and blocked income Mark Martin and Thomas Bettge of KPMG describe the US approach to transfer pricing issues involving blocked income, a problem highlighted by recent and upcoming developments. By Mark Martin & Thomas Bettge June 28 2021
Remarkably unremarkable results for APAs in the midst of COVID-19 Mark Martin and Thomas Bettge of KPMG in the US discuss the IRS’ advance pricing agreement (APA) statistics for 2020 and consider the APA programme in the midst of the... By Mark Martin & Thomas Bettge June 02 2021
ICAP: Taking disputes off the MAP Mark Martin and Thomas Bettge of KPMG in the US explore the International Compliance Assurance Programme as a tool for preventing disputes that would otherwise need to be resolved through... By Mark Martin & Thomas Bettge May 04 2021
US: Coca-Cola TP case – takeaways for taxpayers Mark Martin and Thomas Bettge of KPMG in the US discuss the recent IRS victory in the Coca-Cola case and explore its implications for other businesses. By Mark Martin & Thomas Bettge April 01 2021
US Tax Court holds UK treaty does not protect right to deductions Mark Martin and Thomas Bettge of KPMG in the US explore the conclusion to the Tax Court litigation in the Adams Challenge case, and note key takeaways for other companies. By Mark Martin & Thomas Bettge March 04 2021
