Transfer Pricing

By Kevin Pinner

Many developing countries objected Thursday to including arbitration as an option within a protocol on tax disputes in the United Nations framework convention on international tax cooperation, characterizing the process as tending to be imbalanced.

By Natalie Olivo

Goodyear Tire & Rubber Co. is planning to challenge proposed IRS adjustments that could undermine the company's ability to offset certain taxes related to an intercompany intellectual property sale, according to a U.S. Securities and Exchange Commission filing.

By Natalie Olivo

The Sixth Circuit affirmed an Ohio federal judge's order requiring Eaton Corp. to share performance evaluations for Ireland-based workers with the IRS, holding that the agency's interest in investigating potential tax liabilities outweighs Ireland's privacy interest, which the court said was "weak" at best.

By Kevin Pinner

A number of developing countries argued Monday that gross basis taxation is the easiest-to-administer option for overcoming inequitable transfer pricing rules within a protocol on taxing cross-border services in the United Nations framework convention on international tax cooperation.

By Sanjay Talwani

A whistleblower was correctly denied an award for information about alleged underpayments by a large multinational corporation, the U.S. Tax Court said Monday, finding the information did not substantially contribute to the IRS' action in the case.

By Kevin Pinner

The European Union should pursue a blocwide digital services tax as a counterbalance to its trade agreement with the U.S. and should limit the 15% minimum tax to preserve investment, an Italian business group said, calling the trade deal "appalling."