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Harmful tax practices (e.g., tax havens, preferential tax regimes, tax rulings) are characterised by the propensity to erode tax bases of other countries which allegedly leads to an undesirable race-to-the-bottom on taxation rates.

A recent opinion in the Enron Corporation bankruptcy case provides some insight into a counterparty’s eligibility for protections under the safe harbor provisions of the Bankruptcy Code. In an opinion issued May 3, 2005, the U.S. Bankruptcy Court for the Southern District of New York (the "Bankruptcy Court") ruled that Bear, Stearns International Ltd. ("Bear Stearns") was not immune from an avoidance action related to an equity swap transaction where the payment from Enron to Bear Stearns occurr

Fundraising: Accessing US Venture Capital.

A recent opinion issued by the District Court for the Southern District of New York (the "District Court") may be cause for some alarm among energy traders.

On November 6, 2003, the United States and Japan signed a new income tax treaty to replace the 30-year-old existing treaty and recognize Japan’s status as a major trading partner of the United States.

Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon's victory in a major transfer pricing dispute

In a recent case, Villa-Arce v. Commissioner, a whistleblower sent information to the IRS that he believed showed that the company was using improper transfer pricing practices and taking unjustified deductions.

Aligning international tax strategy with global supply chain planning helps reduce tax exposure, capture incentives, and increase operational agility.

In the dawn years of transfer pricing, when the bulk of international trade focused on tangible goods, relatively little attention was devoted to the analysis of transactions involving services.

On September 17, 2015, the IRS issued a statutory notice of deficiency to the Coca-Cola Company, increasing its federal income taxes for 2007-2009 by $3.3 billion, based primarily on transfer pricing adjustments exceeding $9 billion.

The One Big Beautiful Bill Act (OBBBA) is the latest sweeping change to the tax code—and one that advisors can't afford to ignore.

In a petition recently filed in the U.S. Tax Court, a taxpayer has challenged the Internal Revenue Service (IRS) regulation that provides that the IRS can reallocate income between affiliates even when foreign law prohibits making the payment or receipt in question.

To date, a limit on the duration of trusts in the United States has been a rule of property law, governed by state statute or case law, and has varied from state to state.

Dans une décision qui sera mentionnée aux tables du Recueil Lebon, le Conseil d'Etat apporte des précisions relatives au régime...

In this edition: status of the 385 debt regulations in limbo and Australia takes unilateral action by enacting diverted profits tax.

You are tax director of a multinational corporate group sitting in your office in New York. It is late Friday and, after a difficult week (like every other week), you are looking forward to some time off at the beach.

In ancient Rome, a college of "augurs" would predict the future by observing the flight patterns of birds, examining the entrails of animal sacrifices, or interpreting natural phenomena. While perhaps less colorful, ...