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 COVID-19 pandemic. By Mark Martin & Thomas Bettge June 02 2021
US Tax Court holds UK treaty does not protect right to deductions By Mark Martin & Thomas Bettge March 04 2021
US: New horizons for dispute resolution under pillar one’s Amount A 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
OECD GloBE consultation focuses on details but overall design remains hazy By Mark Martin & Thomas Bettge January 06 2020
New IRS policy restricts telescoping for APA and competent authority resolutions By Mark Martin & Thomas Bettge January 26 2021
US: Thinking through secondary transfer pricing adjustments By Mark Martin & Thomas Bettge October 29 2020
US: Tax Court to decide on foreign taxpayer’s right to deductions in Adams Challenge By Mark Martin & Thomas Bettge August 10 2020
US outbound: US taxing jurisdiction over offshore decommissioning services upheld By Mark Martin & Thomas Bettge February 24 2020
A look at tax liability insurance in the US: Practical considerations By Dean Andrews October 21 2020
Section 163(j): A closer look at inbound financing developments in the US By Mike Knobler & William Skinner September 30 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
COVID-19 and dislocated employees: DEMPE and risk control considerations By Mark Martin & Thomas Bettge July 02 2020
