Blog Archives

Pipe Dream # 3: Can we raise the bar on the type/quality of analysis?

Dealing with IRS, or with taxpayers, in transfer pricing audits can be very frustrating. Today, we routinely have accountants practicing economics, economists practicing law (and, ...

Pipe Dream # 4: Can we get back to the arm’s length standard?

The US pioneered the application of the arm’s length standard to transfer pricing (although the Germans might argue with that), and it seems to be ...

Pipe Dream # 5: Can we recognize that not all intellectual capital is housed in the US? Or, can we take the future of our country into account in devising tax laws relating to transfer pricing?

Departing from transfer pricing for a bit, one of my concerns has long been the future of the US economy. With manufacturing jobs leaving the ...