Matthew Frank, Director of the Internal Revenue Services's Advance Pricing Agreement (APA) programme, explores the benefits of the programme but signals a warning for the less than fully committed
Matthew Frank Director of the Internal Revenue Services's Advance Pricing Agreement (APA) programme explores the benefits of the programme but signals a warning for the less than fully committed
Transfer pricing controversies have a deserved reputation for being expensive prolonged and difficult affairs. The recent Glaxo litigation was filed in US Tax Court in 2004 after lengthy administrative proceedings lasted two and a half years cost the parties untold millions in professional fees addressed twelve tax years stretching all the way back to 1989 and was resolved last month before trial with the company agreeing to write the IRS a...
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Matthew Frank, Director of the Internal Revenue Services's Advance Pricing Agreement (APA) programme, explores the benefits of the programme but signals a warning for the less than fully committed
Matthew Frank Director of the Internal Revenue Services's Advance Pricing Agreement (APA) programme explores the benefits of the programme but signals a warning for the less than fully committed
Transfer pricing controversies have a deserved reputation for being expensive prolonged and difficult affairs. The recent Glaxo litigation was filed in US Tax Court in 2004 after lengthy administrative proceedings lasted two and a half years cost the parties untold millions in professional fees addressed twelve tax years stretching all the way back to 1989 and was resolved last month before trial with the company agreeing to write the IRS a...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
