transfer pricing

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The Multistate Tax Commission plans to announce that they are accelerating their development of a transfer pricing audit program by soliciting the assistance of Dan Bucks, the former MTC Executive Director and Montana Director of Revenue. New Jersey recently asked the MTC to consider hiring transfer pricing auditors to assist in its Joint Audit Program…

By Todd Betor and Andrew Appleby

The Indiana Department of Revenue issued a Letter of Findings denying a taxpayer’s deductions for certain intercompany payments to a subsidiary management company. The taxpayer and its subsidiary management company (Management Co.) entered into an intercompany agreement based on a federal income tax transfer pricing study, which endorsed the…

In a rare open session, the Multistate Tax Commission’s (MTC) Audit Committee (Committee) met yesterday to discuss changing the way the MTC selects companies to audit on behalf of states. For many taxpayers, the MTC’s process for selecting audit targets is a mystery because it occurs behind closed doors. The current selection process requires states…

On March 5, 2013, the Multistate Tax Commission’s Income and Franchise Tax Uniformity Subcommittee declined to move forward with a transfer pricing project and instructed its Financial Institutions Working Group to examine the inclusion of loans in the property apportionment factor. For full details, read our legal alert, “Update from the MTC’s Winter Committee…

The controversial methodology relied upon by several states to assess corporate taxpayers for transfer pricing violations has been ruled invalid by a D.C. Administrative Law Judge. Several revenue authorities, including New Jersey, Alabama, Louisiana, Kentucky and the District of Columbia, have relied on this now invalidated transfer pricing audit methodology to assess corporate franchise and…