Draft Rule 79 sets out recognized methods and comparability criteria for determining arm’s length price under section 165, mandating use of the most appropriate method and current-year data for ...

Rule 81 prescribes dataset construction, weighted averages, and a 35th–65th percentile arm’s length range when multiple comparable prices arise, with the median applied if the transaction falls ...

Countries regulate and tax imported goods through the customs duties they impose at their ports of entry. According to the World Trade Association, a hierarchy of techniques exists to determine the ...

“Other Transaction Authorities” might seem like a risky new acquisition method, but it’s been around longer than the Federal Acquisition Regulation. This is part of a series about other transaction ...

The method further includes determining that access to the first service is conditional upon performance of a first amount of the transaction processing task, and assigning, to the user account, a ...

Forbes contributors publish independent expert analyses and insights. Ryan Finley writes about transfer pricing and international tax. In no case is the IRS’s favored method, the comparable profits ...

Although the regulations offer straightforward grounds for challenging the fanciful transfer pricing method endorsed in Medtronic II, a potential appeal could shed light on broader questions about the ...

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and ...

A computerized method to provide a risk relationship resource allocation tool via a back-end application computer server of an enterprise, comprising: receiving, at the back-end application computer ...