Today's Transfer Pricing Environment
The IRS, OECD and taxing authorities from developed and developing countries have ramped up enforcement efforts with renewed focus on multinational enterprises' ("MNEs") transfer pricing policies.
The OECD implemented revised standards for transfer pricing documen-tation and a template for country-by-country reporting which is recommended to be adopted by MNEs with a revenue in excess of € 750 million and starting fiscal years beginning on or after January 1, 2016. The IRS released final regulations that align U.S. transfer pricing reporting requirements with those recommended by the OECD. Under the final regulations, the reporting requirements apply to fiscal years beginning on or after June 30th, 2016.
MNEs need to be prepared to document and defend the transfers of property, services and intangibles among affiliated entities in this changing regulatory environment, whether under existing regulatory requirements or the new OECD requirements.
Marcum LLP's International Tax Services Group has expertise and technical knowledge to assist in transfer pricing support for clients. This includes:
- Implementation of Transfer Pricing Policies
- Preparation of IRS Required Transfer Pricing Documentation and Audit Defense
- Preparation of OECD and Other Foreign Transfer Pricing Documentation
When MNEs initiate global intercompany transactions, they need to establish pricing for those transactions.
The transfer pricing methodology that an MNE implements should reflect a reasonable return to the parties of the transactions based upon the functions performed, risks assumed and assets utilized. Marcum can assist by preparing benchmark reports that identify comparable transactions to support an arm's length pricing methodology. In addition, Marcum can advise on the implementation of intercompany agreements and other documen-tation to support the transfer pricing policies.
June 13, 2018
Tax Flash - International Taxation
IRS Grants Relief to Taxpayers in Connection with Certain Transition Tax Penalties
On June 4, 2018, the Internal Revenue Service released IR-2018-131, providing that it will waive certain penalties relating to the newly enacted transition tax assessed ....
May 21, 2018
International Taxation
Foreign-Derived Intangible Income
Enacted as part of the 2017 Tax Cuts and Jobs Act, new Internal Revenue Code Section 250 creates a new tax deduction for income derived ....
March 30, 2018
As Seen In
Bloomberg BNA’s Daily Tax Report published Part II of Tax Manager Ragini Subramanian’s article on the complex requirements of expatriation.
In Part 2 of a two-part article, Ragini Subramanian of Marcum LLP walks through determining the value, type, and location of a taxpayer's assets on ....
March 29, 2018
As Seen In
Bloomberg BNA’s Daily Tax Report published Part I of an article by Tax & Business Services Manager Ragini Subramanian about the intricacies of becoming an expatriate.
In Part 1 of a two-part article, Ragini Subramanian of Marcum LLP analyzes factors to consider when contemplating expatriation, including whether the taxpayer is a ....
March 21, 2018
Tax Flash
Farewell to the Offshore Voluntary Disclosure Program: The IRS Pulls the Plug
In spite of its many iterations since 2009 and the 56,000 new taxpayers with their $11 billion added to Internal Revenue Service coffers, on September ....
March 15, 2018
Tax Flash - International Taxation
IRS Issues Notice to Explain New Toll Tax
On March 13, 2018, the Internal Revenue Service issued additional guidance to help taxpayers meet their filing and payment requirements under the new Section 965 ....
February 28, 2018
Tax Flash - International Taxation
Global Intangible Low Taxed Income: A Step Away from Territorial
The new tax reform law has been widely touted by the media as transforming the U.S. into a territorial system of taxation as used by ....
February 23, 2018
As Seen In
The New York Times quoted national Tax Leader Joseph Perry in an article discussing the complexities and confusion created by the Tax Cuts & Jobs Act, and the likely battles yet to come in Congress.
Never mind that once in a generation tax bill that just passed last year. Congress is headed for years more of big fights over taxes, ....
February 21, 2018
Tax Flash - Tax Return Compliance
The Impact of Tax Reform on Financial Accounting
On December 22, 2017, the Tax Cuts and Jobs Act, was signed into law. The Act will have a significant impact on financial reporting issued ....
February 15, 2018
Tax Flash - International Taxation
New IRS Directives Issued for Transfer Pricing Examinations
On January 12, 2018, the Large Business and International Division of the Internal Revenue Service issued five directives which provide instructions on how IRS agents ....
February 13, 2018
Tax Flash - Tax Return Compliance
Bipartisan Budget Act of 2018
The Bipartisan Budget Act of 2018, enacted last Friday, February 9, contains a number of tax breaks for both individuals and businesses. These include the ....
February 12, 2018
As Seen In
The Hartford Business Journal quoted Connecticut Tax Partner-in-Charge Brett McGrath, in an article about the impacts of the Tax Cuts & Jobs Act of 2017.
More than 30 years after digesting the last major federal tax overhaul, Connecticut accountants and legal advisers working to interpret the latest changes to the ....
February 09, 2018
As Seen In
CNBC quoted Tax Principal Michael D’Addio in an article about adjusting paycheck withholdings to comply with the new tax rates for individuals.
In January, the Treasury Department released its income tax withholding tables, updated to reflect changes stemming from the Tax Cuts and Jobs Act. The new ....
February 05, 2018
As Seen In
Bloomberg News quoted Ed Reitmeyer, Philadelphia partner-in-charge of Tax Services, in an article about tax strategies for owners of pass-through businesses under the new tax law.
If exploiting a tax loophole is as much an art as a science, then the tax planning profession is poised for a creative renaissance. The ....
January 30, 2018
As Seen In
Fox Business spoke with Tax Principal Michael D’Addio about the need to adjust paycheck withholdings under the new tax law.
As employees begin to receive their updated paychecks based on the new tax code changes, many are seeing incorrect withholding amounts, which could lead to ....
January 30, 2018
As Seen In
Long Island Business News reported on the Marcum tax panel the publication’s editor is co-moderating with Melville Office Managing Partner Carolyn Mazzenga.
Long Island Business News Editor Joe Dowd and Marcum Melville Office Managing Partner Carolyn Mazzenga are set to moderate a series of panel discussions tonight ....
January 30, 2018
As Seen In
Bloomberg’s Talking Tax podcast invited Tax Principal Michael D’Addio onto the show for a discussion about whether the new tax law will drive pass-through entities to convert to C-Corporation status.
The new tax law lowers the corporate tax rate to 21 percent—a change that some lawmakers have suggested could prompt pass-through entities to convert to ....
January 29, 2018
As Seen In
Long Island Business News quoted State & Local Tax Leader Paul Graney in an article about options New York State is considering to counter the regional tax impact of the federal Tax Cuts & Jobs Act.
Facing new federal rules that limit state and local tax deductions, New York and California are considering options to give their residents a big federal ....
January 29, 2018
As Seen In
CFO.com published an article by Tax Leader Joseph Perry and Tax Principal Michael D’Addio, discussing the pros and cons of C-corporation v. pass-through entity status under the new tax law.
A 21% income tax rate might sound appetizing to some pass‐through entities, but C‐corporation status doesn't suit every organization.
January 24, 2018
As Seen In
Associated Press quoted Tax Principal Michael D’Addio in an article about how small businesses are capitalizing on the new tax law.
Although there are still many unknowns about the tax law that took effect Jan. 1, some small business owners have already figured out that they ....
January 22, 2018
As Seen In
Long Island Business News featured International Tax Co-Leader Doug Nakajima in an article about the repatriation of foreign earnings by U.S. companies.
For many years, many U.S. multinational companies hoarded cash abroad. As long as they didn't bring money they earned abroad back to the United States, ....
January 19, 2018
Tax Flash - State & Local Taxation
U.S. Supreme Court Will Hear South Dakota's Sales Tax Case
On January 12, 2018, the United States Supreme Court decided that it will hear a South Dakota case (State of South Dakota v. Wayfair Inc., ....
January 19, 2018
Press Release
Marcum LLP Designated by IRS as Certified Acceptance Agent
Marcum LLP is now designated a Certified Acceptance Agent (CAA) by the Internal Revenue Service (IRS). The CAA designation establishes Marcum as an agent of ....
January 09, 2018
Tax Flash - Tax Return Compliance
2018 Tax Filing Season Begins January 29
The Internal Revenue Service announced that the nation's 2017 tax season will begin Monday, January 29, 2018. This is to ensure the security and readiness ....
December 22, 2017
Tax Flash - The Tax Cuts and Jobs Act
The Tax Cuts and Jobs Act is Now Law
President Trump signed this legislation into law today. The act is the most significant tax legislation since the Tax Reform Act of 1986.
December 22, 2017
Tax Flash - International Taxation
Transition or Imposition - Shareholders Beware of the 2017 Transition Tax on Foreign Earnings
The transition tax is a mandatory one-time tax to be imposed on U.S. shareholders that own 10 percent or more of the shares of a ....
December 21, 2017
Tax Flash - Tax Reform
The Tax Cuts and Jobs Act is Finally Here, No More Do Overs
This week, Republicans agreed on a final version of the tax reform bill and filed a conference agreement on December 15, 2017.
December 20, 2017
As Seen In
The Los Angeles Times published a follow-up story in collaboration with Marcum, about how taxpayers in various circumstances would fare under tax reform.
Earlier this month, The Times reviewed tax returns submitted by a handful of readers to see how the House and Senate tax plans would have ....
December 20, 2017
As Seen In
Bloomberg Markets Radio had Tax Leader Joseph Perry on the show to discuss aspects of the new tax reform plan.
Bloomberg Markets Radio had Tax Leader Joseph Perry on the show to discuss aspects of the new tax reform plan.
December 19, 2017
IRS Certified Acceptance Agent
Marcum is now an IRS Certified Acceptance Agent
The Protecting Americans from Tax Hikes Act, enacted on December 18, 2015, included provisions that affect the Individual Taxpayer Identification Number application process.
November 17, 2017
As Seen In
MSNBC invited New York City Tax Partner-in-Charge Maury Cartine onto the program to discuss his analysis of how President Trump's 2005 federal tax return would fare under the House Tax Cuts & Jobs bill.
November 17, 2017
As Seen In
Fox News invited national Tax Leader Joseph Perry back to "Happening Now" to continue discussing whether the House and Senate tax reform bills will deliver on their promises to cut taxes for the middle class.
November 14, 2017
Tax Flash
Senate Committee on Finance Issues Version of Tax Cuts and Jobs Act
Last week, the Senate Finance Committee issued its version of the recently released House Tax Cuts and Jobs Act.
November 10, 2017
Press Release
2017 Marcum Year-End Tax Guide Now Available
Marcum LLP has issued its 2017 Year-End Tax Guide in the midst of Congressional efforts to reform the national tax code. This year's tax guide ....
January 03, 2017
International Taxation
New Reporting Requirements by Foreign-Owned U.S. Disregarded Entities
The IRS has recently issued final regulations regarding the treatment of U.S. disregarded entities wholly owned by foreign persons. These final regulations became effective December 13, ....
December 14, 2016
As Seen In
Bloomberg BNA's Daily Tax Report quoted Tax Partner Elizabeth Mullen in an article about transfer pricing controversies currently pending before the U.S. Tax Court.
Some of the best-known companies in the U.S. and the world dispute the IRS’s characterization of expenses they can deduct from transactions with their foreign ....
October 13, 2016
Press Release
Marcum LLP Named Exclusive U.S. Member Firm of ECOVIS International
Marcum LLP has been named the exclusive U.S. member firm of ECOVIS International, a global accounting and advisory network with members in 60 countries on six ....
September 01, 2016
Tax Flash
Apple and Transfer Pricing Turmoil
The European Union's ("EU") antitrust regulator, the European Commission ("Commission"), has changed the way the world looks at transfer pricing and tax favored regimes. Asserting that ....
Transfer Pricing Brochure
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The Marcum 2017 Year-End Tax Guide continues our tradition of providing timely tax guidance for the upcoming year.
Marcum LLP is one of the largest independent public accounting and advisory services firms in the nation, with offices in major business markets throughout the U.S., as well as Grand Cayman, China and Ireland.
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