Author Page: Michael Peggs — Ruchelman P.L.L.C.

Author Page: Michael Peggs — Ruchelman P.L.L.C.

presentations

Featured

Biases, Heuristics, Blind Spots, and Pitfalls in I.R.S. Transfer Pricing Examinations

Inside the Global Tax Practice: A Seminar on U.S. International Tax Planning

Transfer Pricing for Mid-Sized Corporations

articles from insights

Featured

Hooray for New Math: Is It Really a Simplified Transfer Pricing Approach for 2025?

Entering a New Dimension – O.E.C.D. Transfer Pricing Guidance as Hard Tax Law

Medtronic Part Deux: The Best Method Is Yet To Come?

Goodwill and Mister Donut – A Going Concern?

The "Value Creation" Question has Escaped the New Pillar 1 Mousetrap

The Cameco and Glencore Transfer Pricing Cases – Comments on the Common Complications in Commodities Commerce Controversy

Form or Fizz? Coca-Cola Transfer Pricing Decision

Wait No Longer, the Other Shoe Won’t Drop in Denmark

The Do's and Don'ts of I.R.S. Transfer Pricing Storytime

O.E.C.D. to Use Hybrid Model to Develop Digital Economy Nexus and Profit Attribution Rules

O.E.C.D. Unified Approach Garners Less Unified Comments from Europe’s Tech Producers and Users

How Soon Is Now? The O.E.C.D. Starts Work on a Substitute for Unilateral Digital Economy Fixes

Debt Characterization and Deductibility Under Domesticated International Rules

O.E.C.D. Discussion Draft on Financial Transactions – A Listing of Sins, Little Practical Guidance

Managing a Transfer Pricing Exam? Wash Your Hands with Soap and Water

Can the Arm’s Length Standard Beat the R.A.P.? Transfer Pricing After the T.C.J.A.

O.E.C.D. Releases Mutual Agreement Procedure Peer Review Report for the U.S.

Eaton A.P.A. Cancellations Were an Abuse of I.R.S. Discretion

Amazon Makes the C.U.T. – An Important Taxpayer Win, A Reminder to Consider Transactional Evidence

Insights Vol. 3 No. 9: Updates & Other Tidbits

B.E.P.S. Action 7 – O.E.C.D. Calls for Improved International Coordination on the Allocation of Branch Profit

A New Way to Do the Splits: B.E.P.S. Guidance Falls Short of Enabling Global Formulary Apportionment

Transfer Pricing Positions of Consolidated Groups: After Guidant

Country-by-Country Reporting – Where Are We Going?

A Proposed Treatment For H.T.V.I.

Tax Court Strikes Down I.R.S. Position on Stock-Based Compensation in Altera Case

Transfer Pricing Litigation from A to Z

Foreign Correspondence: Notes from Abroad

I.R.S. vs. O.E.C.D. – How Are Tax Authorities Planning to Conduct Your Next Transfer Pricing Audit