Tag Archives: State Transfer Pricing

Loper Bright Is Fuel for Future State Transfer Pricing Challenges

Bloomberg Tax In Loper Bright Enterprises v. Raimondo, the US Supreme Court overturned the 40-year-old Chevron doctrine, which instructed courts to defer to any reasonable agency interpretation of an ambiguous law. This move has led many in the state and local tax community to consider the potential impact on state agencies authorized with administering revenue statutes. Although Loper Bright‘s exact … Continue Reading

State Transfer Pricing Defense Needs Deep Section 482 Analysis

Bloomberg Tax Multinational corporations have long battled the IRS and other nations’ taxing authorities over their transfer pricing arrangements. But transfer pricing examinations and disputes at the state level can be even more challenging due to a lack of consistency and transparency, particularly in states that require entities conducting a unitary business to file separate … Continue Reading
LexBlog