BDO Transfer Pricing Alert - December 2013

December 2013

On December 6, 2013, the Internal Revenue Service released Chief Counsel Advice (“CCA”) Memorandum 201349015, dated September 16, 2013. The CCA addresses the determination of creditable foreign taxes of United States corporations with foreign disregarded entities or branches and notes that United States transfer pricing principles may be relevant in determining whether non-arm’s length transfer prices result in noncompulsory payments of foreign taxes