Welcome to this, Issue No 3 of 2020 of Moore’s Transfer Pricing Brief. This issue has a wholly North American flavour.
Jackie Honeycutt and Paul Currie, from Elliott Davis, set the scene in their broad introduction to transfer-pricing law and practice in the United States, while Nghi Huynh and Jon Davies of Armanino discuss the latest repercussions from the Altera case as it winds its way through the US courts and Nghi comments on the TP Documentation Best Practice FAQs recently published by the IRS. As the COVID-19 pandemic continues to dominate both the political and public-health agenda, Rita Chung from Citrin Cooperman and Christina Leonard from law firm Sandler, Travis & Rosenberg suggest how MNEs with one or more routine entities abroad performing limited-risk functions should revisit their existing transfer-pricing policy and identify opportunities to improve their cash position, while Avinash Tukrel from Canadian firm Segal surveys the impact of COVID-19 on the TP environment in Canada.
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