2025 Transfer Pricing Update with Nghi Huynh

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 11

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Nghi Huynh, Transfer Pricing Partner-in-Charge, Armanino Advisory LLC. Nghi is a proven tax professional with over 20 years of experience in transfer pricing, research, audit, and tax planning projects within Big 4 public accounting firms.

Tune in for these key takeaways:

• An overview of Transfer Pricing models, planning, and industries that commonly utilize this method

• What Transfer Pricing might look like for a small startup company entering into international markets that include mid-size to large competitors

• When and how to enlist assistance with transfer pricing beyond tangible goods (services, IP, cost-sharing, financing arrangements)

• Situations that might call for Advance Pricing Agreements or Mutual Agreement Procedures

• An overview of typical Transfer Pricing documentation, when to refresh, and how best to maintain long-term

• Details about common intercompany funding pitfalls when multinational enterprises establish and expand their foreign operations

• A discussion of a few of the most efficient ways for parent companies to fund foreign subsidiaries (loans, capitalization, short-term AR/AP)

• Updates on the current state of transfer pricing litigation with the IRS and high-risk jurisdictions for audits and adjustments

Learn more about Nghi Huynh:

• Visit the Transfer Pricing page on Armanino’s website: https://lnkd.in/gZHF5hjY

• View Armanino’s website: https://www.armanino.com/

• Connect with Nghi Huynh on LinkedIn: linkedin.com/in/nghi-huynh

• Check out Armanino’s most recent Transfer Pricing newsletter: https://www.linkedin.com/posts/tax-armanino_armanino-tariff-advisory-ugcPost-7371204268365737984-xq5Z/?utm_source=social_share_send&utm_medium=member_desktop_web&rcm=ACoAAADbAhkB5xgWo_NM0eh5PpgcFdl7gNb6C_A

• Follow Armanino on LinkedIn: https://www.linkedin.com/company/armanino/

• Visit Armanino’s YouTube Channel: https://www.youtube.com/c/armanino

• Follow Armanino on Facebook: https://www.facebook.com/Armanino.HQ/

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

• YouTube: https://www.youtube.com/@TheWolfGroupPC

• Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

• Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

• Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

• Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa