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Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Ian Halligan previously led Baker Tilly’s international tax services in the US
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
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Sponsored by Deloitte Transfer Pricing GlobalJobst Wilmanns and Anodri Suchdeve of Deloitte preview ITR’s upcoming transfer pricing change management guide, produced in collaboration with global transfer pricing industry experts from Deloitte.
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Sponsored by KPMG USMark 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 compensation costs under cost sharing arrangements.
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Sponsored by QCG Transfer Pricing PracticeJesús Aldrin Rojas of QCG Transfer Pricing Practice warns taxpayers to properly comply with the obligations of the transfer pricing regime in Mexico.
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