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About Clark Chandler

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So far Clark Chandler has created 18 blog entries.

OECD Recent Handbook on CbC Reporting

The OECD recently released CbC Reporting – Handbook on Effective Tax Risk Assessment.  This guidance is designed to help tax authorities develop an effective approach for using the data contained in the CbC report to assess which taxpayers pose the most – or least – risk from a tax authority perspective.  In addition, this guidance [...]

By | 2017-11-13T01:06:03+00:00 November 8th, 2017|

Allocation of Risk When Control is Shared Among Different Legal Entities

The new OECD Guidance on transfer pricing emphasizes the role of control and decision-making, and essentially states that risk allocations will only be respected if the legal entity that is bearing the risk also controls that risk.  One of the key questions in this regard is what happens when several different legal entities control risk?  [...]

By | 2017-11-13T01:07:39+00:00 September 28th, 2017|

Diving Into the Amazon Transfer Pricing Case

One of the more interesting aspects of the Tax Court’s recent decision in the Amazon transfer pricing case was its treatment of reasonable alternatives.  The IRS argued that the US taxpayer had the “reasonable alternative” of not entering the cost sharing agreement (“CSA”) and that therefore the buy-in payment should reflect the present value of [...]

By | 2017-11-13T01:12:01+00:00 June 21st, 2017|

Why Documentation is So Expensive

Preparing global documentation is expensive. Understanding why it is so expensive is the first step in trying to determine how to lower costs while improving quality. Let's start with some simple arithmetic. The OECD local file template has 20 information requests, 4 asking for legal entity information and 16 asking for information by transaction. For [...]

By | 2017-11-13T01:11:46+00:00 March 27th, 2017|

Transfer Pricing Documentation – Comparing Costs and Benefits

Documentation is expensive, and tax department budgets are finite. Therefore, tax departments face the very common economic problem of how to allocate resources more effectively, a process that starts with the determination of which legal entities need documentation and an evaluation of the type of documentation that is needed. Some tax departments approach this issue with [...]

By | 2017-11-13T20:54:19+00:00 March 27th, 2017|

The Evolution of the Arm’s Length Standard: Part 5 – An Increasing Focus on the Location of Decision-Makers

The OECD's most recent guidance discusses three types of control over decision making and risk: (i) the capability to make decisions to take on, lay off, or decline a risk-bearing opportunity, together with the actual performance of that decision making function, (ii) the capability to make decisions on whether and how to respond to the [...]

By | 2017-11-13T01:11:40+00:00 March 27th, 2017|

Border Adjusted Tax

There has been a lot of interest in proposals to institutes a cash flow border adjusted tax. I have seen a lot of technical presentations, but have often found it difficult to get a precise handle on the likely effects of the tax. So I thought that I would try to address four basic questions [...]

By | 2017-11-13T01:11:02+00:00 March 6th, 2017|

Basics of Setting Up a Visual Dashboard

One of the most immediate and practical issues that that MNEs are facing is how to deal with the large volumes of information that they are expected to collect and present to tax authorities. Visual dashboards – which can now be developed easily using readily available software – are an effective tool for quickly examining [...]

By | 2017-11-13T01:11:25+00:00 March 6th, 2017|

Economics Partners & Greener Equity Deal Announcement

Dr. Timothy Reichert, PhD, today announced that Economics Partners LLC has acquired and merged with Greener Equity, a valuation firm based in American Fork, Utah. “For years, Economics Partners has been a market leader in transfer pricing and complex intangible asset valuation, so we are excited to join forces with Greener Equity to better address [...]

By | 2017-11-13T01:10:53+00:00 February 22nd, 2017|

Building a Risk Scorecard

Over the past decade, the number of countries that require (or at least expect) transfer pricing documentation has increased dramatically. However, the nature of the regulatory requirements and the benefits/cost of providing documentation varies substantially by country. Given the cost of preparing documentation, many MNEs prioritize different countries, designating some as ones where documentation is [...]

By | 2017-11-13T01:10:19+00:00 July 2nd, 2015|