North America
ITR spoke to two US TP experts about the long-running dispute, with one arguing that the case highlights ‘weaknesses’ with the comparable uncontrolled transaction method
Given the US/G7 pillar two deal, the OECD is in danger of being replaced by the UN as the leading global tax reform forum
Cinven’s latest investment follows its acquisition of a stake in Grant Thornton UK in December; in other news, a barrister listed by HMRC as a tax avoidance promoter has alleged harassment
Jennifer Best was most recently the acting commissioner of the IRS’s large business and international division
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the issue of implicit support and a recent IRS advice memorandum addressing transfer pricing for intercompany debt -
Sponsored by KPMG USMultinational companies face numerous year-end tasks but should not forget to file the treaty notifications that are required in certain US tax treaties, say senior tax practitioners from KPMG in the US
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US analyse the 2022 mutual agreement procedure statistics for the US and discuss their significance for businesses
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North American Jurisdictions