By Kat Lucero

Biotechnology giant Amgen is making a "futile" attempt to raise a purported double-taxation issue for tax years 2016 through 2018 in a pair of transfer pricing cases before the U.S. Tax Court, the federal government said, arguing the disputed years fall outside the court's jurisdiction.

By Natalie Olivo

Pharmaceutical giant McKesson asked a Texas federal court to strike down cost-sharing transfer pricing regulations that underpin the company's $10 million tax refund bid, arguing the U.S. Supreme Court's Loper Bright ruling forecloses previous deference to rule writers.

By Molly Moses

The administrative costs for a company or individual triggering a taxable presence, or permanent establishment, in a jurisdiction shouldn't exceed the profit allocable to the entity, transfer pricing specialists said Friday.

By Molly Moses

The use of artificial intelligence in transfer pricing is expected to ease compliance and reduce costs for clients, but multiple questions remain about the technology's potential and how it should be applied, a panel of tax experts said Friday.

By Kevin Pinner

The IRS Office of Chief Counsel has endorsed a company's proposal to reduce certain transfer pricing adjustments through a setoff after retroactively changing how it allocated costs between related companies, according to a memorandum.

By Molly Moses

An international business group urged the U.S. Tax Court to reject IRS arguments that Eaton Corp. deserved a higher credit rating due to its foreign parent's "implicit support," saying the case could significantly affect its members' U.S. tax liabilities.