Transfer Pricing

By Anna Scott Farrell

The Sixth Circuit shouldn't grant Eaton Corp.'s request to curtail arguments in its appeal of a court order enforcing an Internal Revenue Service summons for its European employee records, the federal government argued Thursday, saying it wants the chance to explain why foreign law doesn't apply.

By Kevin Pinner

The U.S. semiconductor industry is considering moving manufacturing operations to the U.S. and elsewhere as a tariff-mitigation strategy with President Donald Trump threatening to levy the sector and its supply chains, professionals told Law360.

By Kevin Pinner

Starbucks leveraged its private certification program for coffee growers to boost profits transferred almost tax-free from Switzerland to the Netherlands to the U.K., amounting to an estimated $1.3 billion between 2011 and 2021, according to a report from a union-funded nonprofit organization.

By David Hansen

CMS said an attorney with more than a decade of experience as a Mauritius government lawyer has joined CMS Prism, the firm's Mauritian affiliate.

By Jack McLoone

The U.S.' proposed adoption of the OECD's approach to pricing certain cross-border transactions, known as Amount B, should go beyond just marketing and distribution activities, the National Foreign Trade Council said Friday, suggesting it be extended to services and other baseline activities.

By Natalie Olivo

The IRS is seeking Eaton employee records that would violate European Union data protection laws, the power management multinational told the Sixth Circuit, arguing that an Ohio district court should accordingly only privately review the documents with "critical guardrails."