Expand the following panels for additional search options.

Global BVU News and Trends October 2019

Business valuation news from a global perspective.

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.

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).

BVU News and Trends April 2019

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

Willamette publishes a ‘Best of Insights’ issue

In commemoration of the 50th anniversary of Willamette Management Associates, the firm has put out a special edition of its Insights publication.

Medtronic, Inc. v. Commissioner (II)

8th Circuit says Tax Court failed to do the required comparability analysis between selected uncontrolled license arrangement and contested intercompany licenses, making it impossible to say whether CUT was the best method for calculating arm’s-length royalty rates in transfer pricing case.

New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles

The Tax Cuts and Jobs Act of 2017 (the Act) brought sweeping changes to the international tax landscape, including the transfer pricing arena. Intangible property is at the core of many of these changes. Plus, the IRS is cracking down on this area.

BVU News and Trends May 2018

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

New tax law’s impact on intangibles

Under the new tax law, intangibles are more broadly defined than under prior law.

Transfer Pricing and the Valuation of Intangibles

Transfer pricing is widely acknowledged as the top international tax issue for multinational companies with related-party (or controlled) transactions. Frequently these transactions involve intangibles, and the transfer prices assigned to such intangibles transactions are among the most heavily scrutinized by tax authorities across the world. Join Kash Mansori and Guy Sanschagrin for an overview of the regulatory environment governing the transfer pricing of intangibles, and a comprehensive discussion on the valuation methods used by transfer ...

CUT Method Prevails in Amazon’s Transfer Pricing War With IRS

: In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says ...

How the expert in the Amazon trademark case determined a royalty rate

In the recent Amazon Tax Court case, the IRS challenged the valuation of trademarks the company transferred to its overseas subsidiary. But Amazon prevailed, and here's an explanation of the comparable uncontrolled transaction (CUT) method its expert used to sift through thousands of transactions.

CUT Method Prevails in Amazon’s Transfer Pricing War With IRS

In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says.

Amazon.com, Inc. v. Commissioner

In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says.

Delaware Supreme Court Judge Boos Chancery's Option Valuation Case Analysis

In reviewing one of the Delaware Court of Chancery's most noteworthy rulings from 2015, one judge on the state Supreme Court wrote a stinging critique of the trial court's analysis.

In Transfer Pricing Case, Tax Court Fails to Perform Adequate CUT Analysis

In transfer pricing case centering on taxpayer’s intercompany licensing agreements, Tax Court finds CUT method is the best way to calculate arm’s-length royalty rates; court accepts taxpayer-proposed uncontrolled comparable but makes adjustments to account for differences in transactions.

Medtronic, Inc. v. Commissioner (I)

In transfer pricing case centering on taxpayer’s intercompany licensing agreements, Tax Court finds CUT method is the best way to calculate arm’s-length royalty rates; court accepts taxpayer-proposed uncontrolled comparable but makes adjustments to account for differences in transactions.

What are cost sharing arrangements (CSAs)?

1 - 25 of 30 results