Although the regulations offer straightforward grounds for challenging the fanciful transfer pricing method endorsed in Medtronic II, a potential appeal could shed light on broader questions about the ...

The comparable profits method is still often cast as uniquely conceptually flawed among transfer pricing methods and only suitable for use as a last resort, but this characterization often draws ...

Globalization presents both tremendous opportunities for business, but also significant challenges. Processing Content On one hand, multinational corporations have access to assets across all their ...