The largest transfer pricing controversy has yet to reach Tax Court. Microsoft has disclosed that it is currently engaged in a long-standing transfer pricing dispute with the IRS over $28.9 billion of ...

Her main areas of specialization include: Funds Transfer Pricing, Interest Rate Risk in the Banking Book, Asset Liability Management and Balance Sheet management through FTP and optimization.

"Introduction of this legislation suggests relief from year-on-year litigation, however, the rules may through light on the unanswered questions including the approach of the transfer pricing ...