Ryan Finley (@ryanmfinley) profile picture

Ryan Finley

@ryanmfinley

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

 Baltimore, MD
taxnotes.com/document-list/contributors-authors/finley-ryan
Joined September 2015
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Photo by Ryan Finley (@ryanmfinley)Photo by Ryan Finley (@ryanmfinley)Photo by Ryan Finley (@ryanmfinley)Photo by Ryan Finley (@ryanmfinley)Photo by Ryan Finley (@ryanmfinley)Photo by Ryan Finley (@ryanmfinley)Photo by Ryan Finley (@ryanmfinley)Photo by Ryan Finley (@ryanmfinley)Photo by Ryan Finley (@ryanmfinley)Photo by 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
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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: taxnotes.com/featured-analys…

Now That the Coca-Cola Appeal Can Begin, What’s at Stake? | Tax Notes

Ryan Finley explains why Coca-Cola’s forthcoming appeal of a Tax Court decision will likely be an uphill battle.

taxnotes.com
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Lots going on in U.S transfer pricing litigation. Here's an overview of some of the highlights. pod.link/TaxNotesTalk
Tax Notes Talk

Tax Notes Talk

Listen to Tax Notes Talk wherever you get your podcasts!

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Replying to @StephanieSoong
@StephanieSoong @TaxStew Bold prediction, courtesy of DALL-E.
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Next time.
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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.
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Ryan Finley retweeted
Tax Notes (@TaxNotes) profile picture
Tax Notes@TaxNotes28 Jul 2023
🚨 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: taxnotes.co/3DvrAyb
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Anyone want to join a movement to stop discussing, reading about, or otherwise paying attention to a farcical MMA fight between clueless billionaires? Alternatively, we can insist that the winner face the 106lbs fifth place winner in NJ’s District 27. We can talk about that.
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For all you Beowulf fans, here’s ChatGPT’s Old English translation of our favorite statute.
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Some helpful tips from ChatGPT.
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I’d hate to beat a dead (figurative) horse, but it appears the (figurative) horse isn’t dead
Tax Notes (@TaxNotes) profile pictureTax Notes@TaxNotes9 May 2023
Perspective: @ryanmfinley explains that the questions raised by Tax Court Judge Cary Pugh about the income method during closing arguments in the #Facebook trial are cause for concern. taxnotes.co/3plvohW
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Always interesting…
Tax Notes (@TaxNotes) profile pictureTax Notes@TaxNotes7 May 2023
Perspective: Philippe G. Penelle explains how to avoid frequent and sizable year-end #transferpricing adjustments by guiding the selection of comparable companies, using a system that encompasses both static and dynamic comparability. taxnotes.co/40Ns7oA
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ChatGPT really nails it on hypermasculine anti-cat bias @StephanieSoong
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A rare heart-warmer from me. ⁦@StephanieSoong⁩ nytimes.com/2023/04/17/us/mu…
An Eagle Who Adopted a Rock Becomes a Real Dad (Published 2023)

An Eagle Who Adopted a Rock Becomes a Real Dad (Published 2023)

Murphy, a bald eagle at a bird sanctuary in Valley Park, Mo., had been incubating a rock, and his keepers did not have the heart to separate them. He seemed ready when an eaglet needed a dad.

nytimes.com
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I wholeheartedly support the proposal by @RobertGoulder for an APA-challenge statute of limitations. taxnotes.com/tax-notes-inter…

Enlightenment Through Sticky Notes: 3M Goes Down  | Tax Notes

In this installment of the Last Word, the author examines the U.S. Tax Court decision in 3M v. Commissioner.

taxnotes.com
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Ryan Finley retweeted
Tax Notes (@TaxNotes) profile picture
Tax Notes@TaxNotes4 Mar 2023
Letter to the Editor: Reuven S. Avi-Yonah considers the Tax Court’s 3M judgment. taxnotes.co/3Z9STaH
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Tax Notes (@TaxNotes) profile picture
Tax Notes@TaxNotes5 Mar 2023
“I think we're only in the sort of early days of how this issue is really going to be decided,” Tax Notes International contributing editor @ryanmfinley said. Listen to the full #podcast interview on the recent Tax Court decision in the 3M case: pod.link/TaxNotesTalk
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Ryan Finley retweeted
Tax Notes (@TaxNotes) profile picture
Tax Notes@TaxNotes7 Mar 2023
Forthcoming U.S. foreign tax credit guidance will likely cover rule order, including the treatment of qualified domestic minimum top-up taxes (QDMTTs), under a new #OECD global minimum tax framework, a U.S. official said. Read more from @StephanieSoong: taxnotes.co/3L4xlrM
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Consolation prize: Jalen Hurts denialism has been officially and permanently discredited. Go Birds.
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#GoBirds
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Unfortunately for 3M (and Coca-Cola), the great First Security Bank opinion may not be all it was cracked up to be.
Tax Notes (@TaxNotes) profile pictureTax Notes@TaxNotes10 Feb 2023
In a major win for the #IRS, the Tax Court has held in a long-awaited decision that key requirements imposed by the blocked income regulations are substantively and procedurally valid. Read the latest from @ryanmfinley: taxnotes.co/3RQGAwU
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