Google’s transfer of intangibles draws IRS attention
Bloomberg reports the IRS is auditing how Google Inc. avoided federal income taxes by shifting profit into offshore subsidiaries, including how the company valued software rights and other intellectual property it licensed abroad. Transfers of intangibles to offshore subsidiaries located in lesser-taxed areas can allow for huge tax savings. Google, for example, is estimated to [...]
NERA seminar addresses impact of recent changes in business valuation practices for transfer pricing studies
NERA, in cooperation with the Tax Executives Institute (TEI), is hosting a tax and transfer pricing seminar on October 19 in NYC. Experts from NERA’s Global Transfer Pricing Practice will provide updates on US international tax legislation and country specific updates on transfer pricing issues in Canada, the UK, Germany, France, Japan, and China. For [...]
Pellegrino chairs BVR Summit on IP valuation; final agenda announced
Plan now to join us in Chicago Sept 15-16 and grow your intellectual property valuation business. Here’s the final program, including the industry-leading faculty and topics. Register here. Wednesday, September 15, 2010 8:00 a.m. – 8:30 a.m. Opening Remarks: Analyze, Defend, and Maximize IP Value Featuring: Mike Pellegrino (Pellegrino & Associates) Conference chair Mike Pellegrino (the author [...]
OECD on transfer pricing: look for updated guidelines in 2011
The Organisation for Economic Co-operation and Development(OECD), which helps member nations strive for better global standards (and which publishes Transfer Pricing Guidelines) will begin to update their transfer pricing guidelines in 2011. OECD’s Working Party No.6 will examine the legal and economic ownership and taxation of intangibles in addition to valuation methods. “The fact that [...]
NERA article on how credit crisis affects transfer pricing valuations
In this issue of Transfer Pricing International Journal, NERA Consultant Amanda Pletz and Senior Consultant Artur J. Bonifaciuk consider some of the lasting issues that multinational enterprises are likely to face in the context of the credit crisis with respect to intra-group financing options, and the repercussions for the area of transfer pricing. Available on the [...]
Veritas case challenges IRS position on transfer pricing valuations
Veritas Software Corp. v. Commissioner, 2009 WL 4723602 (U.S. Tax Court)(Dec. 10, 2009) After aggressively expanding in the 1990s, Veritas Software Corporation became the largest manufacturer of advanced storage management software, holding distribution agreements with leading original equipment manufacturers (OEMs), including Microsoft and HP. Typically, the OEMs bundled the Veritas software into their operating systems [...]
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