MDW explained the IRS Commissioner’s remarks on transfer pricing, hybrid structures, withholding tax, and offshore accounts during the International Tax Conference at George Washington University.
MDW provided a year-end reminder to help taxpayers price their related party transactions on an arm’s length basis.
MDW explained the CRA and IRS audit concerns when taxpayers restructure their business. Disputes often focus on the valuation and price of intangibles. The OECD Discussion Draft proposes new transfer pricing guidance for taxpayers to review.
The Canadian Institute of Management published “Transfer Pricing: what it is, why it matters and what to do” by Matthew Wall.
MDW explained the new US Regulations for pricing related party services and intangibles beginning 1 January 2008.
Matthew Wall spoke at the Canadian Institute of Chartered Business Valuators on “Transfer Pricing: Why it Matters to CBVs”.
MDW provided a year-end checklist to help taxpayers price their related party transactions on an arm’s length basis plus tips for preparing transfer pricing documentation to reduce the risk of an audit, dispute and reassessment by the tax authorities.
MDW explained the CRA’s response to criticism, denying they are not the “world’s most aggressive” for transfer pricing audits.
MDW explained the Federal Budget giving the CRA $30 million to hire more auditors that now use electronic screening and better planning to audit taxpayers that use aggressive tax planning.
MDW explained the CRA’s latest Transfer Pricing Memo (TPM-09) that defines a “reasonable effort” to avoid transfer pricing penalties when preparing “contemporaneous documentation”.