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Global BV News and Trends March 2022

Business valuation news from a global perspective.

Global BV News: OECD issues updated transfer pricing guidelines

A new chapter on financial transactions is in the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which are widely followed.

Gift and Estate Tax Valuation Update

Join Barry Sziklay for important 2021 income and transfer tax valuation cases as well as the valuation aspects of the adequate disclosure regulations required to report a gift for federal transfer tax purposes and start the statute of limitations running. Internal Revenue Code (IRC) Chapter 14 valuations, Special Valuation Rules §§ 2701-2704, will be addressed in a summary fashion given the complexities of the rules required for a valuation to meet the requirements of Chapter ...

Value of Coke’s secret formula could end up in Supreme Court

At last week’s New Jersey CPA Society’s Business Valuation and Litigation Services Conference, Barry Sziklay (Friedman LLP) gave an update on the huge battle between Coca-Cola and the IRS over transfer pricing that involves the trademark and secret formula for the soda giant’s iconic beverage.

Global BV News and Trends August 2021

Business valuation news from a global perspective.

Willamette focuses on tax and transfer pricing

Taxation-related valuation and transfer pricing issues are the focus of summer 2021 Insights from Willamette Management Associates.

Global BV News and Trends June 2021

Business valuation news from a global perspective.

Global BV News: New book on intangibles and transfer pricing

How do you value intangibles in line with the arm’s-length principle that is required internationally for transfer pricing purposes?

Coca-Cola Co. v. Comm'r

Coca-Cola had been applying a transfer pricing method called the 10-50-50 since it entered into a closing agreement with the IRS in 198, covering the years 1987 to 1995. Coca-Cola had consistently followed that transfer pricing method; the IRS had audited Coca-Cola annually and “signed off” on that transfer pricing method for over a decade. Upon examination of Coca-Cola’s tax returns for 2007 to 2009, the IRS determined that Coca-Cola’s transfer pricing methodology did not reflect arm’s-length norms because it overcompensated the supply point and undercompensated Coca-Cola. The IRS reallocated income between Coca-Cola and its supply points employing the comparable profits method (CPM) pursuant to Reg. Sec. 1.482-5. The IRS increased Coca-Cola’s taxable income by over $9 billion assessing over $3 billion in additional taxes!

2020’s Most Important Transfer Pricing Case—Coca-Cola

Coca-Cola had been applying a transfer pricing method called the 10-50-50 since it entered into a closing agreement with the IRS in 1986, covering the years 1987 to 1995. Coca-Cola had consistently followed that transfer pricing method; the IRS had audited Coca-Cola annually and “signed off” on that transfer pricing method for over a decade. Upon examination of Coca-Cola’s tax returns for 2007 to 2009, the IRS determined that Coca-Cola’s transfer pricing methodology did not reflect arm’s-length norms because it overcompensated the supply point and undercompensated Coca-Cola. The IRS reallocated income between Coca-Cola and its supply points employing the comparable profits method (CPM) pursuant to Reg. Sec. 1.482-5. The IRS increased Coca-Cola’s taxable income by over $9 billion assessing over $3 billion in additional taxes!

Book Review: Best Practices: Thought Leadership in Valuation, Damages, and Transfer Price Analysis

A “gem” is what this reviewer calls a new book by Robert F. Reilly and Robert P. Schweihs of Willamette Management Associates.

A ‘gem’ of a book from Reilly and Schweihs

That’s what Roberto H. Castro (Central Washington Appraisal, Economics & Forensics LLC and Gravis Law PLLC) says in his review of Best Practices—Thought Leadership in Valuation, Damages, and Transfer Price Analysis.

Journal of Business Valuation 2017 Edition

From the CBV Institute ...

BVU News and Trends December 2019

A monthly roundup of key developments of interest to business valuation experts.

Global BVU News and Trends December 2019

Business valuation news from a global perspective.

Global BVU News and Trends October 2019

Business valuation news from a global perspective.

Global BV News: Significant transfer pricing case in Australia

In a major victory for the taxpayer, the federal court in Australia found in favor of Glencore, a mining firm, and ruled that the terms between the Glencore Australian subsidiary and its Swiss trader parent for the sale of copper concentrate were within an arm’s-length range.

Details of the CUT method used in the Amazon case

Last week’s BVWire covered the 9th Circuit decision in the Amazon case that affirmed the U.S. Tax Court’s 2017 decision in favor of the company in a transfer pricing case.

UK perspectives on OECD’s upcoming transfer pricing harmonisation efforts

‘Some jurisdictions have acted unilaterally, some have made failed attempts, while some have adopted a “wait and see” approach,’ the current issue of Bloomberg BNA’s Transfer Pricing Forum says.

Global BV News: ‘Quite a ride’ ahead for global transfer pricing

In the latest issue of Bloomberg BNA’s Transfer Pricing Forum, international transfer pricing practitioners provide their insight on how the tax authorities, as well as multinationals in their jurisdictions, are preparing for the anticipated Organization for Economic Co-operation and Development (OECD) harmonized global approach to the digitalization of the economy.

Tax Court’s Amazon valuation ruling stands up to 9th Circuit scrutiny

The 9th Circuit recently affirmed the U.S. Tax Court’s 2017 decision in favor of Amazon in this key transfer pricing case, finding the governing regulations limited the definition of “intangible” to independently transferrable assets.

New transfer pricing requirements and deadlines for UK multinationals with Hong Kong operations

The Hong Kong Inland Revenue Department (IRD) has released Departmental Interpretation and Practice Notes (DIPNs) No. 58 with new transfer pricing filing examples for UK-based enterprises.

9th Circuit Upholds Tax Court’s Valuation of Intangibles in Big Transfer Pricing Case

Appeals court affirms Tax Court ruling favoring taxpayer’s CUT method over IRS’ DCF to value various intangible assets transferred to European subsidiary; governing regulations limit definition of “intangible” to independently transferrable assets, excluding residual business assets, court says.

Amazon.com, Inc. v. Commissioner (II)

Appeals court affirms Tax Court ruling favoring taxpayer’s CUT method over IRS’ DCF to value various intangible assets transferred to European subsidiary; governing regulations limit definition of “intangible” to independently transferrable assets, excluding residual business assets, court says.

Hong Kong issues transfer pricing guidance

The Hong Kong Inland Revenue Department (IRD) has released Departmental Interpretation and Practice Notes (DIPNs) Nos. 58, 59, and 60 and an updated version of DIPN No. 28 related to transfer pricing (TP Guidelines).

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