“A trillion here, a trillion there, pretty soon you’re talking real money.” — with apologies to Everett Dirksen On August 17, the Wall Street Journal reported that nine large technology companies have accumulated roughly $3 trillion in off-balance-sheet commitments, most…
Separate-entity state tax base exposure to international transfer pricing if federal enforcement priorities shift from § 482 to attribution, and why many states already possess the statutory authority to respond without new legislation. “Plurality must never be posited without necessity.”…
Inventory markdown disclosure in U.S. public filings runs on two regulatory tracks. GAAP under ASC 330 sets a narrow trigger that applies only to a defined subset of markdown activity. The SEC overlay under Regulation S-K is where the substantive…
This post builds on my previous one, “Impairment and Amortization: Where Transfer Pricing Analysis Meets GAAP Income Statement Classification,” assuming the Comparable Profits Method (CPM) is chosen under 1.482-1(c) and focusing on building the comparable set. The purpose of this…
Laying the Groundwork This post assumes the Comparable Profits Method (CPM) is the best method under 1.482-1(c), with operating margin after depreciation (OMAD) as the profit indicator (PLI). The key question addressed in this post is whether the operating income…
Transfer pricing industry practice traditionally employs descriptive ratio analysis under 26 CFR 1.482-5(b)(4)(ii) within the Comparable Profits Method (CPM) to determine an arm’s length range.