Willamette focuses on wealth transfer valuation
Estate and gift tax planning and valuation issues are the focus of the Autumn 2022 Insights from Willamette Management Associates.
Latest Inside Look at the ktMINE Royalty Rate Database
“Understand your data” is one of the main tenets of the valuation profession. Brett Schoell gives an up-to-date look at the ktMINE royalty rate database and answers some questions. He is the product lead for ktMINE’s suite of applications, and he supports ktMINE’s transfer pricing and valuation customers.
Global BV News and Trends September 2022
Business valuation news from a global perspective.
Global BV News and Trends August 2022
Business valuation news from a global perspective.
Global BV News: EY releases global transfer pricing guide
The EY Worldwide Transfer Pricing Reference Guide 2020-2021 is designed to help identify transfer pricing rules, practices, and approaches.
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.