Tag Archives: transfer pricing

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

Louisiana Announces a New “Transfer Pricing Managed Audit Program”

The Louisiana Department of Revenue (the “Department”) released Revenue Information Bulletin No. 21-029 announcing the “Louisiana Transfer Pricing Managed Audit Program.”  Beginning November 1, 2021, eligible corporations may request to participate in the program in order to resolve intercompany transfer pricing issues with the Department. Newly registered taxpayers, existing taxpayers, and taxpayers currently under audit … Continue Reading

Bill Backstrom presents on Intercompany Transactions at COST Spring Audit and Income Tax Conference

SALT Team member, Bill Backstrom, recently co-presented “Intercompany Transactions – State Challenges” at the COST Spring Audit and Income Tax Conference in Denver, Colorado. The presentation focused on transactions between related parties and how they attract the attention of state taxing authorities. Tax authorities believe that such transactions provide opportunities for the “redistribution” of income. … Continue Reading

Mississippi Authorizes Contingent-Fee Tax Head Hunters

Department of Revenue Now Authorized to Hire Auditors and Expert Witnesses on Contingency Fees $1,000,000 Appropriation to Fund Contingency Contracts RFPs Quickly Issued for Transfer Pricing Audits and Underreported Cash Sales The Mississippi Legislature recently authorized the Department of Revenue to hire third party tax auditors and expert witnesses and to pay them contingency fees … Continue Reading
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