MDW explained the IRS changes including a new Large Business & International (LB&I) division, led by a transfer pricing director and a chief economist, with 875 more staff added to the existing 600, focusing on tax, valuations and transfer pricing.
MDW explained the OECD received a big response from the tax community for its upcoming project on the Transfer Pricing Aspects of Intangibles including the use of valuation methods.
MDW explained the major changes to the OECD Transfer Pricing Guidelines including revisions to Chapters I-III on Transfer Pricing Methods, new Chapter IX on Business Restructuring, and the proposed review of Chapter VI and VIII on Intangibles.
MDW explained the IRS’ new form requiring taxpayers to report uncertain tax positions (UTP) including valuations and transfer pricing. This will help the IRS in selecting what taxpayers to audit, which transactions to focus on, and how to staff these …
The Financial Post interviewed Matthew Wall for its article on the actions taken by the CRA to examine offshore bank accounts.
Matthew Wall was the chairperson of Infonex’s Transfer Pricing Conference and one of the presenters that spoke on Business Restructuring: Transfer Pricing, Valuation and Audit Concerns.
Matthew Wall submitted an expert report to legal counsel on transfer pricing for an appeal in the Tax Court of Canada.
MDW explained the IRS reached a landmark settlement with a Swiss bank regarding thousands of offshore accounts held by U.S. taxpayers. This has led to thousands of Canadian taxpayers coming forward to pay their taxes before the CRA finds them.