CRA has advised a major software company on a series of IP transactions in response to US tax reform and BEPS, including terminating a qualified cost sharing arrangement as well as valuations for ORIP purposes in the UK, onshoring IP into Ireland and withholding on IP licensing in Germany pursuant to Section 49.
US Tax Court favors unspecified method to determine royalty rate
The first US transfer pricing court decision of 2022 was published on Thursday, August 18, 2022, specifically Medtronic, Inc. and Consolidated Subsidiaries v....