Edward L. Froelich
Morrison & Foerster LLP
Articles
A general introduction to transfer pricing in USA
USA - July 16 2020 This article provides a general overview of the law and practice surrounding transfer pricing in USA, including broader taxation issues and the outlook for future developments.
Spotlight: preparing and filing transfer pricing documentation in USA
USA - July 16 2020 An examination of the legal and practical considerations surrounding the preparation and filing of transfer pricing documentation in USA, with particular regard to recent developments.
IRS Issues New Guidance and Proposed Form 1040 Question Regarding Virtual Currency
USA - October 17 2019 Last week the IRS issued a Revenue Ruling, FAQs, and a revision to draft Schedule 1 to Form 1040 regarding various aspects of virtual…
Amazon Prevails in Ninth Circuit - Government Opportunism Rejected
USA - September 16 2019 Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon’s victory in a major transfer pricing dispute.[1] The decision…
Preparing and filing transfer pricing documentation in USA
USA - July 23 2019 An overview of the legal and practical considerations surrounding the preparation and filing of transfer pricing documentation in USA.
