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The U.S. Court of Appeals for the Eleventh Circuit recently held that a mortgage refinancing could qualify as a bankruptcy-related tax free transaction, even though the deal took place between two nondebtors and did not involve property from the bankruptcy estate.

On the flip side, when the group earns significant profits, the low-risk entity will continue to record the same limited profit margin.

In outsourcing agreements, customers typically request a so-called "Most Favored Customer" or "Most Favored Nation" clause from their service provider.

The 2020 Annual Report suggests that certain foreign competent authorities may have been more successful than others in overcoming COVID-19 disruptions.

Tax-exempt section 501(c)(4) organizations are defined by the Internal Revenue Code as "social welfare organizations.

The inaugural meeting (via conference call) of the Multistate Tax Commission's Committee (Committee) addressing transfer pricing issues (ALAS) took place on April 7, 2016, and was certainly interesting.

Benchmarking—the process of screening, selecting, and analyzing comparable companies—is time consuming. Analysts can spend innumerable hours every year preparing transfer pricing documentation...

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting...

The Inflation Reduction Act of 2022 (IRA), passed into law on August 16, 2022, represented a shift in the world of U.S. federal tax enforcement. This shift—or as most might suggest...

The Bankruptcy Abuse Prevention and Consumer Protection Act of 2005, which becomes effective in most instances in bankruptcy cases filed on or after October 17, contains numerous changes that impact cases arising in the health care industry.

The Service issued a notice warning against improper charitable deductions by taxpayers when taxpayers make payments or easement transfers to exempt organizations in connection with a taxpayer’s purchase of property from the exempt organization. In Notice 2004-41, the Service announced that it "intends to disallow [certain] deductions and may impose penalties and excise taxes" connected with these transfers.

Hollister was planning to set up a manufacturing facility in north India. The company had existing facilities in the US and Europe and was looking to establish its first new manufacturing facility in over 30 years.

The Transfer Pricing (TP) coordination group of the Dutch Tax Authorities (DTA) recently published an internal note, Opzet en aandachtspunten TP‑analyse, explaining how inspectors are expected to prepare...

The client is a manufacturer and distributor of plantbased sweeteners for the global food and beverage industry. Nexdigm multi-functional support to the client included...

With the allure of tax incentives for foreign derived intangible income and an increase in foreign audits scrutinizing transfer pricing, bringing intellectual property (IP) back to the United States...

On August 6, 2015, the IRS and the Treasury Department announced their intention in Notice 2015-54 to issue regulations under Sections 721(c), 482, and 6662 of the Internal Revenue Code.

In April, the IRS released a practice unit on country-by-country (or "CbC") reporting. The purpose of the document is twofold: (i) describe the background of CbC reporting...