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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?

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).

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.

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