Ryan Finley

@TaxNotes contributing editor covering transfer pricing. Fan of Philly sports & animals (except modern humans). No interest in cryptocurrency. Go Birds.

[Ryan Finley @ryanmfinley]

How about that Apple decision? I just wish more people would put up links to the judgment that everyone's seen by now. @StephanieSoong

[Ryan Finley @ryanmfinley]

@PHLEaglesNation Flip them, especially Clara. I don't think Jordan Love wants people saying that crap on his behalf

[Ryan Finley @ryanmfinley]

For anyone with time to kill and a burning interest in the tax affairs of the sugar-water industry, allow me to suggest the following:

https://t.co/kPnsDxFtvk

[Ryan Finley @ryanmfinley]

@goodtaxtakes @Brad_Setser @taxleonard (Assuming I took your meaning correctly.)

[Ryan Finley @ryanmfinley]

@goodtaxtakes @Brad_Setser @taxleonard I also don't think Treasury/IRS have the statutory authority to wipe out CSAs and proverbially sow salt into the soil. They most certainly don't have the inclination. And taxpayers could set up economically similar arrangements without calling them CSAs even if they could and did

[Ryan Finley @ryanmfinley]

@goodtaxtakes Many, myself included, agree with a lot of what Avi-Yonah says. Many others, myself sometimes included, benefit from reading stuff of his they don't entirely agree with. Not everyone feels that way, and that's cool. But there's nothing particularly cultish about any of it.

[Ryan Finley @ryanmfinley]

@InternationlTax Congrats, Mindy!

[Ryan Finley @ryanmfinley]

Lots going on in U.S transfer pricing litigation. Here's an overview of some of the highlights.

https://t.co/TIjmm8VGPu

[Ryan Finley @ryanmfinley]

@SteveDalytax Go raibh maith agat. I look forward to reading yours.

[Ryan Finley @ryanmfinley]

@SteveDalytax Important usage tip - Hiberno-English may differ on this point, but in American English "kept" may more apt than "aged" to refer to something that went bad in a matter of weeks.

[Ryan Finley @ryanmfinley]

Next time.

[Ryan Finley @ryanmfinley]

@StephanieSoong @TaxStew Bold prediction, courtesy of DALL-E.

[Ryan Finley @ryanmfinley]

@StephanieSoong @TaxStew Indeed.

[Ryan Finley @ryanmfinley]

ChatGPT's suggestion for an attorney fighting game. Our protagonist is obviously the tax lawyer -- the opponent seems to be an injured personal injury lawyer.

[Ryan Finley @ryanmfinley]

@taxleonard It's crazy how every installment of this genre uses a method (formulary apportionment) that has been repeatedly considered and repeatedly rejected.

[Ryan Finley @ryanmfinley]

@goodtaxtakes What's frustrating about this genre is that the baseline for what companies "should" have paid (formulary apportionment) has been repeatedly proposed and repeatedly rejected, both at national and multilateral levels. Right or wrong, that's just not how it works.

[Ryan Finley @ryanmfinley]

@StephanieSoong I've proposed "ALTERNATIVE ᚠ" (Fehu) and "alternative ᚢ "(uruz), but so far no takers

[Tax Notes @TaxNotes]

🚨 New podcast episode: @StephanieSoong chats with @ManalCorwin, the new @OECDtax director, about Corwin's vision for the organization.

They also discuss the latest updates on the inclusive framework and two-pillar project. Listen now: https://t.co/g38dOomJhg