Law360 | 4 Ways Tax Pros Say Pandemic has Changed Their Practice

Last year’s historic demand with a smaller staff compounded 2021’s challenges for the Advance Pricing and Mutual Agreement Program (APMA). Our International Tax Group delves into this year’s annual report to evaluate trends and paths for success.

Our International Tax Group analyzes the report on the IRS’s Advance Pricing and Mutual Agreement Program and identifies important insights and trends for advance pricing agreements.

Our International Tax Group examines how the Organisation for Economic Co-operation and Development’s new guidance reiterates the central role of the arm’s-length standard and provides guideposts for taxpayers and tax administrations as they analyze how the COVID-19 pandemic is affecting intercompany pricing.

Can a parent take on losses? Or should the subsidiary incur losses due to risks it assumed? Our International Tax Group investigates the nuances of regulations from U.S. and international agencies and offers actions multinational enterprises can take now to prepare for the tax implications of COVID-19-related disruptions.