I vividly remember a conversation I had with a client during my professional services days. We had drafted a Polish transfer pricing report and had used German comparables to benchmark the German entity that was providing management services to a Polish affiliate.  The client was adamant that Poland would not accept these comparables, because, at ...

Cases like Coca-Cola, 3M, and Medtronic cases have emboldened the IRS when it comes to taking on transfer pricing disputes. And if the courts continue to side with the agency through the appeals processes, then the IRS is potentially looking at billions of dollars in payouts.   Experts expect the IRS to allocate a large portion ...

Our Experts Weigh In on Western Digital’s $1.6-billion Tax Bill Remote work has its advantages, but it has taken its toll on our watercooler chats. Still, some industry happenings are so interesting, they’re worth a Zoom face-to-face to hash it all out. Western Digital’s recent $1.6-billion tax settlement is one of them. But then we’ve ...

A former client of mine, a U.S.-based marketing firm, shared all kind of intellectual property with its subsidiary in Canada. It developed the Canadian firm’s marketing strategy. It maintained an informative website that provided global sales strategies for strategic marketing, innovative email campaigns and contemporary graphic design, and it created all of the marketing content ...