“Profits” in Profit Split Methods: Hazardous Crossovers on the way to Global Formulary Apportionment

By Robert Robillard - 16 November 2017

Profit split methods have had global formulary apportionment inclines lately. This second piece on profit split methods was recently published in Tax Analysts: ““Profits” in Profit Split Methods: Hazardous Crossovers on the way to Global Formulary Apportionment”, Tax Notes International, October...

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RBRT Comments on Transactional Profit Splits in the BEPS Context

By Robert Robillard - 13 October 2017

The OECD recently released the comments received on its latest discussion draft on transactional profit splits in the context of the Base Erosion and Profit Shifting initiative (BEPS). These comments along with the comments received on the latest discussion draft on...

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OECD Transfer Pricing Guidelines 2017 Available

By Robert Robillard - 13 July 2017

On July 10, 2017, the OECD released its 2017 Edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. This 2017 edition of the OECD Transfer Pricing Guidelines contains all the changes and modifications stemming from the BEPS initiative which...

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Practice Makes Perfect: IRS Releases New International Practice Units

By Robert Robillard - 23 March 2016

This blogpost originally appeared on rbrt.ca. The IRS has been busy releasing 10 new practice units: 03-18-2016 Inbound Resale Price Method Routine Distributor 03-18-2016 Computing Foreign Base Company Income for US Individual Shareholders 03-17-2016 Concepts of Foreign Personal Holding Company...

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Canada: CRA releases TPM-17 The Impact of Government Assistance on Transfer Pricing

By Robert Robillard - 21 March 2016

This blogpost originally appeared on rbrt.ca. On March 2nd, 2016, the CRA issued TPM-17 The Impact of Government Assistance on Transfer Pricing. The new TPM-17 is available here. Paragraph 3 explains: "A Canadian resident corporation (CanCo) provides products or services...

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Canada-European Union: Comprehensive Economic and Trade Agreement (CETA)

By Robert Robillard - 3 March 2016

This blogpost originally appeared on rbrt.ca. Recently, Global Affairs Canada indicated that: ["o]n February 29, 2016, Canada’s Minister of International Trade, Chrystia Freeland, and the European Union’s Commissioner for Trade Cecilia Malmström announced the completion of the legal review of...

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Slap Me in the Face: Altera Corp. & Subs. v. Commissioner (Cost Sharing Arrangement)

By Robert Robillard - 13 August 2015

This blogpost originally appeared on rbrt.ca. In Altera Corp. & Subs. v. Commissioner, the IRS got slapped in the face. TaxProf Blog (Paul L. Caron, Editor) writes in "Hickman: The Tax Court Delivers An APA-Based Smackdown": "In Altera Corp. &...

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