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On August 13, 2021, the IRS released a Chief Counsel Advice ("CCA") (CCA 202132009) addressing the tax treatment of intercompany reimbursements of the Branded Prescription Drug ("BPD") fee...

After a nearly decade-long dispute with the IRS, the U.S. Tax Court ordered Coca-Cola to pay $3.4 billion in additional taxes.

Medtronic Inc. & Consolidated Subsidiaries v. Commissioner (T.C. Memo. 2016-112) is the latest defeat for the U.S. Internal Revenue Service ("IRS") in a string of transfer pricing losses.

On 16 September 2014, the OECD released the report on the tax challenges of the digital economy under its Action Plan on Base Erosion and Profit Shifting.

The U.S. Court of Appeals for the Federal Circuit, reviving a controversial decision by the U.S. International Trade Commission, has held that a package license that includes "nonessential" patents along with "essential" patents, at no additional charge for the nonessential patents, is not per se patent misuse.

The enactment of H.R. 1, formerly known as the Tax Cuts and Jobs Act ("TCJA"), on December 22, 2017 marks the first major overhaul of the U.S. federal income tax system in over 30 years.

On April 16, 2019, the Internal Revenue Service Large Business and International division released an overview of three new compliance campaigns, including a captive services providers campaign.

After Altera's victory in Tax Court in 2015,[1] many companies with cost sharing arrangements ("CSA") ceased sharing stock-based compensation ("SBC") costs.

As January 20, 2021 approaches and the advent of a new president and presidency emerges, what can we expect from a Biden administration and its Customs and Border Protection...

The Tax Relief Act of 2010 fundamentally altered wealth transfer planning by substantially increasing the gift tax and generation-skipping transfer (GST) tax exemptions, which are now each $5,120,000.

The Trump administration has recently advanced a series of initiatives that significantly expand the scope of U.S. economic protectionism, targeting foreign tax practices perceived as discriminatory against American interests.

A Self-Canceling Installment Note (SCIN) is a technique used to sell an asset, usually shares or partnership interests in a closely held family business, in exchange for an interest-bearing promissory note. An appropriately structured SCIN will remove the future appreciation in the family business from the seller’s estate. In addition, if the seller dies prior to the maturity of the promissory note, the then-outstanding principal amount of the note may be excluded from the seller’s gross estate.

On January 9, 2026, the final text of the Supplementary Law ("LC") No. 225/2026 was published in the Official Gazette of the Federal Government, which launches the Taxpayers´ Defense Code (the "Code").

African governments are rapidly modernising their approach to tax and customs in the resources sector. Fiscal tools, tighter compliance frameworks and procedural reforms are reshaping investment and operational conditions across the continent.

With the return of 100% bonus depreciation, CFOs can now offset capital investments faster and improve post-tax ROI.

Below is a high-level timeline summarizing developments associated with Hungary's Advertisement Tax.

IRS proposes regulations outlining a series of factors that it will consider in determining whether the tax exemption of an organization, which has engaged in one or more intermediate sanctions violations should be revoked.