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.
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 (I)
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.