Molly Moses

Sean Foley, who died suddenly in September, was a devoted husband, father, brother and friend and a brilliant colleague. He was one of the world’s top experts in an area of international tax known as transfer pricing, where he became the global leader of KPMG’s practice.

Sean Foley, who died suddenly in September, was a devoted husband, father, brother and friend and a brilliant colleague. He was one of the world’s top experts in an area of international tax known as transfer pricing, where he became the global leader of KPMG’s practice.

In negotiations over the streamlined transfer pricing approach for baseline marketing and distribution functions known as Amount B, the U.S. has resisted calls for additional scoping criteria that would exclude more companies from the safe harbor, a former U.S. Treasury economist said Friday.

An Internal Revenue Service supervisor’s sign-off on a transfer pricing penalty for Microsemi was “woefully inadequate” to meet statutory requirements for penalty approval, the semiconductor manufacturer told the U.S. Tax Court.

When one company buys another for its intellectual property, the subsequent pricing of that asset between the now-related entities should reflect the value of what was acquired, transfer pricing specialists said Tuesday at a conference in Washington, D.C.

Countries’ ability to make further adjustments for geographic differences in the streamlined transfer pricing approach known as Amount B — part of the OECD’s plan for reallocating taxing rights among jurisdictions — is “still on the table,” an official from the organization said Tuesday.

In allocating risk among different components of a business for transfer pricing purposes, analysts need to consider governments’ varying interpretations of guidance from the Organization for Economic Cooperation and Development, a panel of economists said Wednesday.

Tax authorities including the Internal Revenue Service are overstepping in their use of "realistic alternative" arguments, substituting their own judgment for that of businesses, transfer pricing specialists said Thursday.

A California couple wasn't eligible for an other-state tax credit for unincorporated business tax paid in New York because the tax is a local levy, paid to New York City and not the state, the California Office of Tax Appeals said.

A North Carolina cellphone retailer wasn't obliged to remit tax on sales of prepaid wireless cards because the cards are gift cards that can be used for nontaxable services and sales, an attorney for the company told the state Supreme Court on Tuesday.