![professional tax software reviews 2013 professional tax software reviews 2013](https://s36394.pcdn.co/wp-content/uploads/2021/02/Yelp-review-1-1030-e1622029317362.png)
As a result of the Xilinx case, the IRS revised Treas.
![professional tax software reviews 2013 professional tax software reviews 2013](https://www.nerdwallet.com/assets/blog/wp-content/uploads/2022/02/GettyImages-1359420140.jpg)
2010), the IRS made the same argument and lost. 6253-12, 9963-12, the IRS asserts that unrelated party comparable data is irrelevant in determining whether parties to a cost sharing agreement must include stock-based compensation. While the US supports the arm's-length standard internationally, domestically the IRS itself has sought to undermine the arm's-length standard in recent transfer pricing disputes and in the cost sharing regulations.
#Professional tax software reviews 2013 how to
Robert Stack, deputy assistant secretary for international tax affairs with the US Treasury and the US delegate to the OECD, recently said the US wants a thorough discussion paper on the arm's-length principle that deals with how to price hard-to-value intangibles. The US Treasury, although it has its own discomfort with the arm's-length standard (as discussed below), is not supportive of the OECD's efforts. No country wants to lose revenue as a result of a transfer pricing "special measure". It will be difficult to build a consensus among countries on the application and administration of "special measures". The concept of a "special measure" involves subjectivity and vagueness, which obscure the arm's-length standard.Ī "special measure" by its very nature suggests a movement away from a consistent pricing methodology. The OECD is considering circumstances in which related-party contracts can, or should be, ignored under a "special measure". § 1.482-1(b)(1), the standard to be applied "in every case" under Section 482 is the arm's-length standard.Īccording to the OECD BEPS discussion drafts: "Special measures, either within or beyond the arm's-length principle, may be required with respect to intangible assets, risk and over-capitalisation", to address purported flaws in the transfer pricing system. It is a simple concept that can be applied consistently. However, in for the past year, at least, it has been under significant attack as a result of the OECD's base erosion and profit shifting (BEPS) papers.Īrm's-length principles are based on what unrelated parties would agree to under similar circumstances. The arm's-length standard has served as the foundation of the world's transfer pricing for the last half century.