Alexander Hamilton Award
Michael Mundaca is co-director of the Americas Tax Center and the National Tax Department at the global professional services firm EY. Just prior to taking on those roles, Michael Mundaca served in the United States Treasury Department’s Office of Tax Policy, during both the Bush and Obama administrations (and he had previously served during the Clinton Administration). During the Obama administration, he served as the Assistant Treasury Secretary for Tax Policy, at the appointment of the President, advising Treasury Secretary Tim Geithner on all matters relating to tax policy and representing the United States in various international forums, including the Organisation for Economic Co-operation and Development. Upon leaving the Treasury Department in 2011, Michael Mundaca received the Alexander Hamilton Award.
The Treasury’s Alexander Hamilton Award is the highest honor bestowed by the department. Established in 1955, the award is conferred not by nomination or vote but rather is chosen personally by the secretary of the Treasury.
A former assistant treasury secretary for tax policy with the US Treasury Department, Michael Mundaca now serves as Ernst & Young’s (EY) co-director of the Americas Tax Center and National Tax Department. In those roles, Michael Mundaca provides client-driven services that focus on US and international taxation rules and developments.
A recent EY Global Tax Alert drew focus to Nicaraguan transfer pricing rules, which went into effect in late June 2017. Enacted as law by the Nicaraguan Congress in 2012, the rules were intended to go into effect four years later (entry into force was later delayed an additional year).
Transfer pricing comes into play when company divisions transact with one another and are measured and treated as entities that are independently run. The newly implemented Nicaraguan rules require the preparation of transfer pricing documentation each year and incorporate the arm’s-length principle. They also set forth transfer pricing methods employed when applying the arm’s-length principle, as well as criteria that taxpayers must adhere to when undertaking a comparability analysis.