This blog presents a basic analytical framework for understanding the relationship between GDP growth and public debt commitments. The Harrod-Domar principle, which posits that increased gross private domestic fixed non-residential investment drives GDP growth, does not apply to the recent GDP growth of many countries.
A discussion of the possible issues in the recently settled transfer pricing dispute between Western Digital Corp. and the United States IRS.
Harold McClure explores intercompany financing issues through the lens of a recent case before the EU General Court and an upcoming battle between Perrigo and the IRS.
International tax law firms are rightfully warning clients of audit risks with respect to intercompany financing in France. Taxpayers can mitigate risk by following new OECD guidance, providing sound economic analysis and avoiding overly aggressive positions on group vs. standalone credit ratings.