Who’s Afraid of the APA?: The Application Of Administrative Law To Tax Regulations

By David Shakow The Supreme Court’s decision in Mayo Foundation for Medical Education and Research v. United States means that tax practitioners must be more sensitive to administrative law and judicial deference to administrative rules.  This includes gaining some familiarity with the Administrative Procedure Act (APA) and the major cases that deal with judicial deference … Continue reading Who’s Afraid of the APA?: The Application Of Administrative Law To Tax Regulations

Transfer Pricing and How to Handle the “Double-Edged Sword”

By David L. Bernard TaxBlawg’s Guest Commentator, David L. Bernard, is the former Vice President of Taxes for Kimberly-Clark Corporation, a past president of the Tax Executives Institute, and a periodic contributor to TaxBlawg. Transfer pricing among affiliated companies is the classic “double-edged sword”. When carefully designed, transfer pricing practices can cut a company’s effective … Continue reading Transfer Pricing and How to Handle the “Double-Edged Sword”