For better or worse, the tax department does not own the chart of accounts (COA). And from a provision perspective, that’s a problem. Why? Allow me to climb up on my soapbox. Most companies do not maintain a COA that differentiates transactions in a manner that allows automation. For us tax people that makes it ...

Vietnam has implemented a very interesting interquartile range requirement for transfer pricing analyses prepared for Vietnam. In their regulations, the tested party must fall within the 35th to 75th percentiles of the arm’s length range, rather than the more traditional 25th to 75th. As Duke University professor Eddy Malesky points out in this podcast, “Audits ...

Back in the 80s, an artist called Rockwell released the song, “Somebody’s Watching Me,” a popular record that at one point climbed all the way to number two on Billboard’s Top 100.  Fast-forward to 2022, and paranoia about being “watched” feels miscast in the social media age, where we are anxious to share everything, from ...

For a lot of people—certainly those from my generation—the word  “control”  brings back memories of Janet Jackson’s 1986 hit album, “Control.” Produced by the legendary Jimmy Jam and Terry Lewis, the album is about how Janet took control of her life and career.    “It is all about control and I’ve got lots of it…”  While ...

If you’ve ever played poker, then you must be familiar with the art of the bluff: You hold a beatable hand, but you act like you’re holding a royal flush. You project a daringly neutral face, and instead of contemplating all that you have to lose, you boldly raise, in hopes that your opponents will ...

There are two schools of thought when it comes to comparables searches for transfer pricing analyses: Should you use publicly listed companies, which most likely means that the comparables will be regional in nature; or should you include privately held companies so that comparable searches are specific to the tested party’s jurisdiction? Tax authorities like ...

Growing up, I thought I would be one of three things: a doctor, a lawyer, or a backup dancer for Janet Jackson. I never thought that I would end up in tax, let alone, a specialized niche of international tax like transfer pricing. But of course, I was also fascinated by technology—and that’s what led ...