Transfer Pricing

By Anna Scott Farrell

Apple must provide the Internal Revenue Service with a Swiss user's internet and phone records as part of a criminal investigation by Switzerland's taxing authority, a California federal judge ruled, despite the man's protests that the records are unrelated to taxes.

By Molly Moses

The IRS is taking an "extreme" position in its defense of a $2.7 billion tax ruling against Coca-Cola by asserting that the standard prohibiting arbitrary and capricious actions by an agency doesn't apply to it, the company told the Eleventh Circuit.

By Natalie Olivo

Facebook asked the U.S. Tax Court to reject the IRS' proposed royalty rate and other calculations for the social media giant's deal with an Irish affiliate to develop intangibles, arguing the agency is attempting to recharacterize the transaction.

By Natalie Olivo

The Internal Revenue Service soon will begin accepting applications for its compliance assurance process real-time audit program for 2026, the agency announced Monday.

By Kevin Pinner

Many developing countries objected Thursday to including arbitration as an option within a protocol on tax disputes in the United Nations framework convention on international tax cooperation, characterizing the process as tending to be imbalanced.

By Natalie Olivo

Goodyear Tire & Rubber Co. is planning to challenge proposed IRS adjustments that could undermine the company's ability to offset certain taxes related to an intercompany intellectual property sale, according to a U.S. Securities and Exchange Commission filing.