BorderCrossings … with EY transfer pricing and tax professionals - May 2025

Continuation of OECD/G20 Pillar One update and other topics

The May BorderCrossings webcast will continue the prior webcast’s discussion on some of the technical aspects of Pillar One Amount A as well as the broader historical “formulary apportionment versus arm’s length” debates. Other topics include the implications of the recent IRS Generic Legal Advice Memorandum on the Commensurate-With-Income standard and the evolution of IRS and other revenue-authority interpretations of long-standing guidance.

Panelists

• Bill Morgan, Managing Director, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP. Bill was previously with the US Treasury Department where, among other things, he represented the United States at Working Party 6 of the OECD during the Pillar One work.
• Mike McDonald, Managing Director, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP.

EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax