Overview It started sometime last year, during the fourth quarter.  The morning business show Squawk Box began to mention “ESG” on a daily basis.  Sometimes it was one of the hosts, sometimes it was a guest. Then. there were two inflection points that marked a higher level of discourse.  First, on December 17, 2019, SEC…

Executive Summary Issue There are three primary drivers that must be considered when looking at oil and gas prices.  First, they are commodities, and move with the complex economics of global supply and demand.  Second, they are very volatile.  And third, they can be significantly influenced by global, geopolitical factors. Challenge The challenge for anyone…

Executive Summary Issue It takes time and money to go through a Chapter 11 restructuring, so going through it twice in a couple of years is unwise and inefficient.  Recently, it has been an issue with companies operating in the energy complex.  The challenges and complexities of energy markets make reorganization plans hard to properly…

Executive Summary Issue The term Environmental, Social & Governance, commonly called “ESG,” is not a new concept. It was a hot topic before the COVID pandemic, in discussions to measure and value how companies engaged in sustainable and societally beneficial activities. It will return as a topic across the business, regulatory, and investment communities again…

OECD Aligning Transfer Pricing In December of 2015, the US issued proposed regulations related to the implementation of OECD/G20 Base Erosion and Profit Shifting (BEPS) Project, Action 8-10 – Aligning Transfer Pricing Outcomes with Value Creation. (Have we lost you yet?) These proposed regulations would require US Multi-National Enterprises (MNEs) with annual revenues of $850…

CbC Not For Me? Think Again. OECD Aligning Transfer Pricing In December of 2015, the US issued proposed regulations related to the implementation of OECD/G20 Base Erosion and Profit Shifting (BEPS) Project, Action 8-10 – Aligning Transfer Pricing Outcomes with Value Creation. (Have we lost you yet?) These proposed regulations would require US Multi-National Enterprises…

US multi-nationals have long enjoyed the simplicity and tax certainty afforded by Cost Sharing Arrangements (CSA). In a CSA, participants share in the development of valuable intangibles in exchange for the right to exploit the resulting intangible. The cost of the development activity is allocated to the participants based on each participant’s expected benefit. (To…

Apple Eurozone Tax 348 million If there was any doubt regarding the changing international tax landscape, Apple became among the first of what is sure to be many multi-national enterprises to enter into a multi-million dollar tax settlement related to its European operations.  Italy’s La Republicca announced last week that Apple has agreed to pay…

Spotlight on Transfer Pricing The US Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released the much-anticipated US Country-by-Country (CbC) Reporting rules on December 21, 2015. These proposed rules, issued in the form of proposed regulation §1.6038-4, would require the ultimate US parent of a multi-national enterprise (MNE) group with annual revenues exceeding $850…

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