US: New horizons for dispute resolution under pillar one’s Amount A Mark Martin and Thomas Bettge of KPMG in the US describe the Amount A tax certainty process in the recently released pillar one blueprint and explore how it might work in practice. By Mark Martin & Thomas Bettge November 19 2020
US: Foreign-controlled CFCs - assessing the regulations for dealing with downward attri... By Mike Knobler & William Skinner October 28 2020
Section 163(j): A closer look at inbound financing developments in the US By Mike Knobler & William Skinner September 30 2020
US: Tax Court to decide on foreign taxpayer’s right to deductions in Adams Challenge By Mark Martin & Thomas Bettge August 10 2020
OECD GloBE consultation focuses on details but overall design remains hazy By Mark Martin & Thomas Bettge January 06 2020
US: Thinking through secondary transfer pricing adjustments By Mark Martin & Thomas Bettge October 29 2020
Transfer pricing remains crucial as IRS CAP programme opens for 2021 By Mark Martin & Thomas Bettge September 29 2020
US transfer pricing market: Stop thinking about risk and seize the opportunity By Oleg Rak September 23 2020
US outbound: US taxing jurisdiction over offshore decommissioning services upheld By Mark Martin & Thomas Bettge February 24 2020
US Outbound: OECD’s unified proposal on pillar one poses challenges for dispute resolution By Mark Martin & Thomas Bettge December 17 2019
US outbound: OECD statistics show continued effectiveness of MAP cases globally and in US By Mark Martin & Thomas Bettge October 15 2019
A look at tax liability insurance in the US: Practical considerations By Dean Andrews October 21 2020
COVID-19 and dislocated employees: DEMPE and risk control considerations By Mark Martin & Thomas Bettge July 02 2020
EU mandatory disclosure impending for certain transfer pricing arrangements By Mark Martin & Thomas Bettge April 27 2020
Transfer pricing implications of COVID-19: Revisiting pricing, contracts, and APAs By Mark Martin & Thomas Bettge April 15 2020
US Outbound: CSA netting for BEAT should still work despite Treasury’s reticence By Mark Martin & Thomas Bettge January 29 2020
