Articles and Technical Resources
- Transfer Pricing 101 – A basic introduction to transfer pricing and key questions every multinational enterprise should ask.
- U.S. Transfer Pricing Penalty Regime Summary – Summary discussion of the U.S. accuracy-related tax penalties. Important information for companies with transfer pricing considerations.
- Cost-Sharing and Transfer Pricing in the U.S. – Discussion of the new Temporary U.S. Treasury Regulations that govern the sharing of costs between multinational enterprises with respect to the development of intellectual property. Companies doing research and development (R&D) cross-border should be aware of the impact of these Temporary Regulations on their business.
- Tax Implications of the Proposed Affordable Health Choices Act of 2009 – Article published by LexisNexis 10/12/2009.
- Economic Substance, Tax Benefits, and Schering-Plough v. U.S. – Article published by LexisNexis 11/02/2009.
- Economic Substance Doctrine and Schering-Plough v. U.S. – Podcast released by LexisNexis 12/01/2009.
- Tax Court’s year-end 2009 decision in Veritas v. Comm’r – Podcast released by LexisNexis 02/22/2010.
- Recent Codification of the Economic Substance Doctrine in the U.S. – Podcast released by LexisNexis 05/17/2010.
