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The U.S. enters into bilateral investment treaties ("B.I.T.'s") to protect and promote foreign investment.

Just after midnight on December 17, 2010, Congress made welcome changes to our gift, estate, and generation-skipping transfer tax system--at least during the period from 2010 through 2012.

In February 2021, the Organisation for Economic Co-operation and Development issued a handbook linked with the official roll-out of its International Compliance Assurance Programme.

In 1964, the Mexican government introduced Maquiladoras as a strategy to attract foreign investment and increase industrialization on the Mexican border. Maquiladora's process, produce, transform...

On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services' (IRS) cost-sharing regulations under code section 482 that says taxpayers have to take into account, among other costs, the costs of stock-based compensation.

$20.5 Billion is the reported amount of Medtronic Corp.'s earnings held by its overseas subsidiaries.

President Trump has signed into law a comprehensive tax reform package that permanently extends several expiring provisions of the Tax Cuts and Jobs Act (TCJA) and enacts key tax measures central to his 2024 reelection...

With the release January 29, 2019 of an important tax policy note (the "Note"), the OECD has introduced greater direction for its BEPS mandate to introduce proposals to address the tax challenges of the "digitalization" of the economy.

The weeks leading up to Congress' summer recess may be decisive.

In 2018, the IRS reminded exam teams to perform a "diligent penalty analysis" in every transfer pricing case. Since then, we have observed that the agency is increasingly...

In this article, we delve into the intricacies of valuing individual legal entities as part of a legal entity rationalization, exploring some of the key considerations that must be considered to prepare a robust...

As the economy improves, industry experts are forecasting a pick-up in the pace of mergers and acquisitions. If you’ve been thinking of selling your company, now is a good time to assess the situation and position yourself to take advantage of opportunities as they unfold. Here are some tips to help you get organized.

On March 22, 2022, the Internal Revenue Service's Advance Pricing and Mutual Agreement Program released its 2021 Announcement and Report Concerning Advance Pricing Agreements.

Technology companies with international operations are increasingly using global tax avoidance methods, despite growing opposition from the public and politicians in the U.S. and abroad.

The parties recently completed briefing on an IRS motion for partial summary judgment in Western Digital Corporation v. Commissioner.

The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7...

On May 27, 2022, the OECD released two public consultation documents related to the tax certainty aspects of Amount A.