Transfer Pricing

By Kevin Pinner

Australia will consider granting exemptions to public country-by-country reporting of tax information to companies that can demonstrate their compliance would reveal commercially sensitive information, violate Australian or foreign laws or negatively impact national security, according to final guidance issued by the Australian Taxation Office.

By Molly Moses

A U.S. Tax Court judge asked an IRS expert Wednesday about his calculation of a standalone credit rating for Eaton's U.S. group in 2012, when it acquired an Irish entity and inverted, noting that the expert, unlike ratings agency Standard & Poor's, factored in Eaton's debt to the Irish parent.

By Molly Moses

A U.S. Tax Court judge asked one of Eaton's experts Tuesday how much the company could have saved by issuing debt from its new Irish parent in 2012 instead of having the parent guarantee bonds the U.S. company issued to third parties.

By Natalie Olivo

Facebook parent Meta Inc. is challenging a nearly $16 billion tax bill stemming from an agreement with an Irish affiliate to share the costs of developing intangibles, telling the U.S. Tax Court that the IRS can't relitigate issues the court already addressed.

By Molly Moses

Eaton is telling "different stories at different times" about the ability of its foreign parent company to step in and pay the U.S. company's debt obligations to third parties, Tax Court Judge Albert Lauber said in questioning one of the company's experts Friday.

By Josh White

A Brussels court referred a case to the Court of Justice of the European Union concerning whether transfers of U.S. taxpayer data breach EU privacy law, according to a court document released Thursday.