CRA assisted a software company with the integration of acquired technology into an existing qualified cost sharing arrangement with consideration of the appropriateness of carve-outs. Additional work included the alignment of functional returns for acquired subsidiaries with the transfer pricing policies of the acquirer.
Measuring and mitigating harm from discriminatory taxes
In the article the authors examine the April 2 Executive Order signed by President Trump highlighting US trading partners’ nontariff barriers, such as...