Shows
TP Talks - PwC's Global Transfer Pricing podcastSpecial Edition – Financial Transactions Transfer PricingIn this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) sits down with Kristina Novak (Transfer Pricing Principal, PwC US) Michael Douglas (Transfer Pricing Director, PwC Ireland), and Jake Roche (Transfer Pricing Director, PwC Australia) to discuss tax controversy with respect to intercompany financing, focusing on recent case law. They examine the challenges posed by tax authorities when it comes to benchmarking interest rates and the factors that influence these decisions, including credit risk assumptions and implicit guarantees. The speakers delve into the approaches of tax authorities in different jurisdictions, including Ireland...2025-06-0329 minTP Talks - PwC's Global Transfer Pricing podcastSpecial Edition – Financial Transactions Transfer PricingIn this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) sits down with Kristina Novak (Transfer Pricing Principal, PwC US) Michael Douglas (Transfer Pricing Director, PwC Ireland), and Jake Roche (Transfer Pricing Director, PwC Australia) to discuss tax controversy with respect to intercompany financing, focusing on recent case law. They examine the challenges posed by tax authorities when it comes to benchmarking interest rates and the factors that influence these decisions, including credit risk assumptions and implicit guarantees. The speakers delve into the approaches of tax authorities in different jurisdictions, including Ireland...2025-06-0329 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 112: Special Edition – Financial Transactions Transfer PricingIn this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) is joined by Shereen Osman (Financial Services Assurance Director and PwC’s Global Islamic Finance practice co-leader, PwC UAE) and Zachary Noteman (PwC’s Middle East Financial Transactions TP Leader). They discuss aspects of Islamic financing and its intersection with transfer pricing. They then explore what Islamic (or Sharia) financing entails and its distinguishing characteristics, including examples of financing that meet the criteria. Finally, they discuss the similarities and differences in returns between Islamic and conventional financing, the benchmarking of Islamic financial tran...2025-02-1420 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 112: Special Edition – Financial Transactions Transfer PricingIn this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) is joined by Shereen Osman (Financial Services Assurance Director and PwC’s Global Islamic Finance practice co-leader, PwC UAE) and Zachary Noteman (PwC’s Middle East Financial Transactions TP Leader). They discuss aspects of Islamic financing and its intersection with transfer pricing. They then explore what Islamic (or Sharia) financing entails and its distinguishing characteristics, including examples of financing that meet the criteria. Finally, they discuss the similarities and differences in returns between Islamic and conventional financing, the benchmarking of Islamic financial tran...2025-02-1420 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 108: Special Edition – Financial Transactions Transfer PricingDebt capacity In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium), Stan Goldenberg (M&A Transfer Pricing Director, PwC US), Andrew Cotterill (Transfer Pricing Senior Manager, PwC UK), and Ben Pietersen (Eurasian Transfer Pricing Director, PwC Georgia) discuss debt capacity from a transfer pricing perspective, exploring the principles and practices of the US, UK, Georgia, and other Eurasian countries. The discussion underscores the nuanced and fact-specific nature of debt capacity analysis across different jurisdictions, with varying implications for taxpayers.Support the show2024-11-0744 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 108: Special Edition – Financial Transactions Transfer PricingDebt capacity In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium), Stan Goldenberg (M&A Transfer Pricing Director, PwC US), Andrew Cotterill (Transfer Pricing Senior Manager, PwC UK), and Ben Pietersen (Eurasian Transfer Pricing Director, PwC Georgia) discuss debt capacity from a transfer pricing perspective, exploring the principles and practices of the US, UK, Georgia, and other Eurasian countries. The discussion underscores the nuanced and fact-specific nature of debt capacity analysis across different jurisdictions, with varying implications for taxpayers.Support the show2024-11-0744 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 95: Special Edition – Financial Transactions Transfer Pricing (June 2023)FTTP Q2 2023: Debt capacity and transfer pricingIn this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Martin Cazaux (Transfer Pricing Principal, PwC US), and Tony Koivula (Transfer Pricing Manager, PwC Finland) discuss debt capacity and transfer pricing, focusing on the US’s and EU’s history of looking at debt capacity, the varying approaches to analyzing debt capacity, Australia’s draft legislation on proposed new interest limitation rules, debt serviceability, and reassessment of debt capacity and double taxation.Support the show2023-06-1922 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 95: Special Edition – Financial Transactions Transfer Pricing (June 2023)FTTP Q2 2023: Debt capacity and transfer pricingIn this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Martin Cazaux (Transfer Pricing Principal, PwC US), and Tony Koivula (Transfer Pricing Manager, PwC Finland) discuss debt capacity and transfer pricing, focusing on the US’s and EU’s history of looking at debt capacity, the varying approaches to analyzing debt capacity, Australia’s draft legislation on proposed new interest limitation rules, debt serviceability, and reassessment of debt capacity and double taxation.Support the show2023-06-1922 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 92: Special Edition – Financial Transactions Transfer Pricing (March 2023)FTTP Q1 2023: A looking ahead (and back) on financial markets and what to expect from tax authoritiesIn this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Dan Pybus (PwC’s EMEA Financial Transactions TP Leader), Bob Ritter (PwC’s US Financial Transactions TP Leader), and Hiral Mistry (Transfer Pricing Partner, PwC Australia) discuss changing financial market conditions, tax policy changes, what to expect from tax authorities in 2023, as well as a look back at 2022.Support the show2023-03-2021 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 92: Special Edition – Financial Transactions Transfer Pricing (March 2023)FTTP Q1 2023: A looking ahead (and back) on financial markets and what to expect from tax authoritiesIn this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Dan Pybus (PwC’s EMEA Financial Transactions TP Leader), Bob Ritter (PwC’s US Financial Transactions TP Leader), and Hiral Mistry (Transfer Pricing Partner, PwC Australia) discuss changing financial market conditions, tax policy changes, what to expect from tax authorities in 2023, as well as a look back at 2022.Support the show2023-03-2021 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 85: Special Edition – Financial Transactions Transfer Pricing (June 2022)In this TP Talks podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Michel van der Breggen (Transfer Pricing Partner, PwC Netherlands), Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), and Rui Yuan (Transfer Pricing Manager, PwC Netherlands) talk about sustainable financing and what it means for transfer pricing. They first share some observations on the sustainable wave in the capital markets. The panelists then discuss some of the potential transfer pricing challenges that are expected to emerge with the current rapid developments in sustainable financing. Support the show2022-06-1421 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 85: Special Edition – Financial Transactions Transfer Pricing (June 2022)In this TP Talks podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Michel van der Breggen (Transfer Pricing Partner, PwC Netherlands), Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), and Rui Yuan (Transfer Pricing Manager, PwC Netherlands) talk about sustainable financing and what it means for transfer pricing. They first share some observations on the sustainable wave in the capital markets. The panelists then discuss some of the potential transfer pricing challenges that are expected to emerge with the current rapid developments in sustainable financing. Support the show2022-06-1421 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 83: Special Edition – Financial Transactions Transfer Pricing (March 2022)In this podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Ed Baghdasarayan (Transfer Pricing Partner, PwC Australia), Dan Pybus (Transfer Pricing/EMEA Financial Transactions TP Leader, PwC UK), and Bob Ritter (US Financial Transactions Transfer Pricing Leader) discuss the 2022 outlook for financial markets and policy environment, focusing on trends with regard to interest rates and debt leverage; ESG and sustainable financing; transfer pricing court cases; other general tax initiatives impacting financing; key takeaways from the US final regulations on the LIBOR transition; emerging practices in the market regarding intercompany finance policies; and cryptocurrency.Support the show2022-04-0528 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 83: Special Edition – Financial Transactions Transfer Pricing (March 2022)In this podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Ed Baghdasarayan (Transfer Pricing Partner, PwC Australia), Dan Pybus (Transfer Pricing/EMEA Financial Transactions TP Leader, PwC UK), and Bob Ritter (US Financial Transactions Transfer Pricing Leader) discuss the 2022 outlook for financial markets and policy environment, focusing on trends with regard to interest rates and debt leverage; ESG and sustainable financing; transfer pricing court cases; other general tax initiatives impacting financing; key takeaways from the US final regulations on the LIBOR transition; emerging practices in the market regarding intercompany finance policies; and cryptocurrency.Support the show2022-04-0528 min
Supreme Court Oral Arguments[20-807] LeDure v. Union Pacific Railroad CompanyLeDure v. Union Pacific Railroad Company
Justia (with opinion) · Docket · oyez.org
Argued on Mar 28, 2022.Decided on Apr 28, 2022.
Petitioner: Bradley LeDure.Respondent: Union Pacific Railroad Company.
Advocates: David C. Frederick (for the Petitioner)
Colleen E. Roh Sinzdak (for the United States, as amicus curiae, supporting the Petitioner)
J. Scott Ballenger (for the Respondent)
Facts of the case (from oyez.org)
Bradley LeDure is a conductor for Union Pacific Railroad Company. In August 2016, LeDure reported for work at a rail yard in Salem, Illinois, to...2022-03-281h 41
SCOTUS Oral Arguments and OpinionsOral Argument: LeDure v. Union Pacific Railroad Co. | Case No. 20-807 | Date Argued: 3/28/2022 | Date Decided: 4/28/2022LeDure v. Union Pacific Railroad Co. | Case No. 20-807 | Date Argued: 3/28/2022 | Date Decided: 4/28/2022Question Presented: [cannot locate]Holding: [NO INFORMATION]Result: Voting information not foundVoting Breakdown: ?-?. Voting breakdown not foundLink to Opinion: Here.Oral Advocates:For Petitioner: David C. Frederick, Washington, D.C.; and Colleen E. Sinzdak, Assistant to the Solicitor General, Department of Justice, Washington, D.C. (for United States, as amicus curiae.) For Respondent: J. Scott Ballenger, Washington, D.C.2022-03-281h 41TP Talks - PwC's Global Transfer Pricing podcastEpisode 69: Financial Transactions Transfer Pricing – March 2021In this Special Edition Financial Transactions Transfer Pricing podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Tanja Keser (Transfer Pricing Partner, PwC Germany), Erin Venter (Transfer Pricing Partner, PwC New Zealand), and Agustin Aila (Transfer Pricing Senior Manager, PwC Argentina) discuss new developments, including pending legislation in Germany related to new requirements for interest deductions; New Zealand’s recently enacted Restricted Transfer Pricing rule for inbound related party debt; and new rules in Argentina impacting intercompany financing. The group also discusses debt capacity and controversy generally.Support the show2021-03-3128 minTP Talks - PwC's Global Transfer Pricing podcastEpisode 69: Financial Transactions Transfer Pricing – March 2021In this Special Edition Financial Transactions Transfer Pricing podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Tanja Keser (Transfer Pricing Partner, PwC Germany), Erin Venter (Transfer Pricing Partner, PwC New Zealand), and Agustin Aila (Transfer Pricing Senior Manager, PwC Argentina) discuss new developments, including pending legislation in Germany related to new requirements for interest deductions; New Zealand’s recently enacted Restricted Transfer Pricing rule for inbound related party debt; and new rules in Argentina impacting intercompany financing. The group also discusses debt capacity and controversy generally.Support the show2021-03-3128 min
PwC Deutschland Transfer Pricing PodcastHighlights of the Global TP Conference and the future of financial transactionsPodcasts from the PwC Global Transfer Pricing Conference 2020
Podcasts from the PwC Global Transfer Pricing Conference 2020
In this first podcast of the series, we provide a brief recap of our Global TP Conference, but more importantly focus on recent developments in the area of financial transactions. Lorenz Bernhardt (TP Partner PwC Germany), Marianna Dozsa (TP Partner PwC Austria) and David Ledure (TP Partner PwC Belgium) will discuss the above mentioned topics.2021-02-0430 min