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

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

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

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