The Tax Cuts and Jobs Act (TCJA) included a provision (section 14221) that appears to be an attempt to retroactively change the interpretation of code sections 367 and 482 regarding the required valuation method for the transfer of intangible property (IP) rights in the context of outbound restructuring transactions, as well as in intercompany transfer pricing arrangements.
In this article originally published by Tax Notes, A&M Managing Director Philip Antoon and Senior Adviser Kenneth Brewer discuss the implications of the TCJA’s changes to the rules for valuing IP.
Click here to read the full article >
Under the Hood: Transfer Pricing in the Thai Auto Parts Sector
March 18, 2026
Thai Auto Parts sector overview, tiers, value drivers, and transfer pricing strategies for MNEs operating in Thailand.
SINGAPORE’S GST INVOICENOW: Working Backwards from 2031
March 18, 2026
Prepare for GST InvoiceNow by working backward from 2031. Align governance, data, and ERP design; standardize processes; embed tax logic to reduce risk.
FCA Overturns TCC in DAC Investments GAAR Decision
March 13, 2026
GAAR clarity: Anti-deferral for CCPCs cannot be circumvented by international continuance; DAC’s plan failed.
Accounting Implications: Turning Tax Outcomes Into Financial Insight
March 12, 2026
Tax outcomes embedded in finance processes enable real-time provisioning, governance, and modelling, aligning forecasts with the P&L for faster decisions.
