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Due to the enormous amount of electronic data stored by companies in the modern era, discovery requests can involve millions of documents which need to be reviewed prior to being turned over to the opposing party.

The headline news about the U.S. Tax Court's decision on the value of Michael Jackson's estate might have been a shock to some – or, perhaps, to many.

It should be clear that a transfer price determined not to reflect the market price or book value cannot be a ground for the licensing authority to block the transfer by refusing the issuance of its approval.

Tax practitioners frequently struggle when providing advice on some cases in areas of tax law that have limited statutory guidance and a sizable body of case law.

When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.

On September 28, 2022, the OECD published the Bilateral Advance Pricing Arrangement ("BAPA") Manual. The manual proposes best practices for jurisdictions to streamline...

The Report on Action 15 of the BEPS action plan (the "Report") was released in September 2014. The goal of Action 15 is to streamline and simplify the implementation of the other BEPS-related measures.

On January 30, 2013, the US Treasury Department proposed amendments to existing gain recognition agreement regulations.

The IRS and Treasury Department have issued proposed regulations addressing the allocation of deductions to foreign-source income under Section 951A, while recent Tax Court decisions clarify critical issues surrounding the Section 245A dividends-received deduction, consolidated return consents, and penalty assessment procedures. These developments carry significant implications for multinational corporations navigating foreign tax credit limitations and domestic loss calculations.

Today, the Arm's-Length Adjustment Service Committee ("ALAS Committee") of the Multistate Tax Commission met via teleconference to move forward with its transfer-pricing program.

On March 22, the Ninth Circuit issued its opinion affirming the opinion of the United States Tax Court in Xilinx, Inc. v. Commissioner.

On September 9, 2021, the Treasury Department and the Internal Revenue Service ("IRS") issued its Priority Guidance Plan for 2021-2022.

On April 15, 2020, OECD released the report titled "Tax and Fiscal Policy in Response to the Coronavirus Crisis: Strengthening Confidence and Resilience" (the "COVID-19 Response").

On March 22, 2016, South Dakota Governor Dennis Daugaard signed into law Senate Bill 106, which requires any person making more than $100,000 of South Dakota sales or more than 200 separate South Dakota sales transactions to collect and remit sales tax.

The public perception is well-established now that international rules are unfit when it comes to taxing digital companies such as Amazon

The IRS's plan to be more selective about which companies apply for advance approval of their transfer pricing transactions could shorten the application process...

The Organization for Economic Cooperation and Development recently held its annual tax conference in Washington, DC.