IRS Update

Matthew Wall Tax

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.

Year-End Checklist

Matthew Wall Transfer Price

MDW provided a year-end reminder to help taxpayers price their related party transactions on an arm’s length basis.

CRA and IRS Update

Matthew Wall CRA Updates, Tax

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 Journal

Matthew Wall Transfer Price

The Canadian Institute of Management published “Transfer Pricing: what it is, why it matters and what to do” by Matthew Wall.

IRS Update

Matthew Wall Tax

MDW explained the new US Regulations for pricing related party services and intangibles beginning 1 January 2008.

CICBV Presentation

Matthew Wall Transfer Price

Matthew Wall spoke at the Canadian Institute of Chartered Business Valuators on “Transfer Pricing: Why it Matters to CBVs”.

Year-End Checklist

Matthew Wall Tax, Transfer Price

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.

CRA Update

Matthew Wall CRA Updates

MDW explained the CRA’s response to criticism, denying they are not the “world’s most aggressive” for transfer pricing audits.

CRA Update

Matthew Wall CRA Updates

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.

CRA Update

Matthew Wall CRA Updates

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”.