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545 results found

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  • Article

    Tax Year 2024 Changes, Planning For Businesses To Consider

    Although only a few areas of tax law had significant changes for 2024, many companies experienced operational and economic changes that could change their tax strategies. Here are a few considerations to keep...
    United StatesTax
    Kaufman Rossin
    Kaufman Rossin
  • Article

    Amazon Makes The C.U.T. – An Important Taxpayer Win, A Reminder To Consider Transactional Evidence

    In finding for the taxpayer in a recent transfer pricing decision, the U.S. Tax Court followed its own determination in Veritas in valuing a buy-in payment made as compensation...
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
Article

Income Shifting: Common Ownership Or Control Under Code §482 In An Inbound Transaction

The Large Business and International Division of the I.R.S. ("LB&I") periodically develops international practice units ("I.P.U.'s") that serve as training material ...
United StatesTax
Ruchelman PLLC
Ruchelman PLLC
  • Article

    Obama Administration's 2013 Budget Proposal Includes Key Changes To Income Tax And Transfer Tax Provisions

    On February 13, 2012, the Obama administration presented its revenue proposals for fiscal year 2013.
    United StatesTax
    Duane Morris LLP
    Duane Morris LLP
  • Article

    OECD Holding Public Consultation On The Tax Challenges Of Digitalization

    The Organisation for Economic Co-operation and Development (OECD) will kick off tomorrow a public consultation on its most recent foray into the tax challenges arising from the digitalization
    United StatesMedia, Telecoms, IT, Entertainment
    Akin
    Akin
  • Article

    Global Tax Risk Program Requires Deep Transfer Pricing Knowledge

    The International Compliance Assurance Program is a voluntary program that helps companies assess international tax risks to quickly achieve greater tax certainty across multiple jurisdictions...
    United StatesTax
    Fenwick
    Fenwick
  • Article

    I.R.S. Identifies Regulations Imposing Undue Burden On Taxpayers

    On April 21, 2017, President Trump issued Executive Order 13789 (the "Order") with the objective of identifying and reducing tax regulatory burdens imposed by Treasury Regulations (the "Regulations").
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Managing Accounting And Tax Compliance In Foreign Markets

    Global expansion is high in the agenda for many US companies but along with new opportunities it also brings tax and accounting challenges.
    United StatesTax
    TMF Group BV
    TMF Group BV
  • Article

    Ninth Circuit Appellate Court Overturns Tax Court In Altera Case

    On June 7, 2019 the Ninth Circuit released their decision on the appeal
    United StatesTax
    Duff and Phelps
    Duff and Phelps
  • Article

    Strategies For Overcoming Transfer Pricing Challenges

    The practice of transfer pricing involves assigning value to goods, services, and intangible property traded between legally distinct but related entities under a common...
    United StatesTax
    Bennett Thrasher
    Bennett Thrasher
  • Article

    Tax Liability Insurance - M&A And Beyond

    During the diligence phase of a transaction, it is not uncommon for a buyer to identify potential tax liabilities that may be caused by a number of situations...
    United StatesTax
    Ankura Consulting Group LLC
    Ankura Consulting Group LLC
  • Article

    Why The IRS Just Made It Easier To Reduce BEAT Exposure On Intercompany Services

    The IRS has confirmed that the BEAT SCM exception can apply, even when SCM is not used as the primary transfer pricing method.
    United StatesTax
    MGO CPA LLP
    MGO CPA LLP
  • Article

    Transfer Pricing Times: 2017 Tax Reform - Transfer Pricing Opportunities?

    In this edition: 2017 tax reform, important new requirements for Luxembourg finance company tax rulings and ATO hubs practical compliance guide
    GlobalTax
    Duff and Phelps
    Duff and Phelps
  • Article

    Frequently Asked Questions About International Tax And Supply Chain Realignment

    Cross-border supply chain changes can trigger exit taxes, compliance penalties, and tax inefficiencies if not planned with international tax in mind.
    United StatesTax
    MGO CPA LLP
    MGO CPA LLP
  • Article

    Multilateral Advance Pricing Agreements

    As transfer pricing examination and controversy continue to grow, it’s becoming increasingly common for a multinational enterprise group to have advance pricing agreements (APA) with more than two countries (typically referred to as a multilateral APA).
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    Newsletter Tax - Transfer Pricing Ecuador

    The Internal Revenue Service in Ecuador established regulations in regards to indirect expenses in order to apply a deductibility threshold for these expenses when calculating the Income Tax for Ecuadorian taxpayers...
    United StatesTax
    Dentons
    Dentons
  • Article

    IRS Updates: ERC Disclosure And Claim Withdrawal Opportunity And Other New Compliance Initiatives

    With regular operations back in full force, the IRS and federal government are giving additional attention to tax compliance.
    United StatesCorporate/Commercial Law
    Kaufman Rossin
    Kaufman Rossin
  • Article

    SDNY Dismisses SEC Reg FD Claim; Cites Excessive Scrutiny of Particular Words Used During Communications with Institutional Investors

    On September 1, 2005 United States District Judge George B. Daniels, of the Southern District of New York, dismissed the Securities and Exchange Commission’s civil action for claimed violations of Regulation FD (Full Disclosure) ("Reg FD") against Siebel Systems, Inc., its Chief Financial Officer ("CFO") and a Senior Vice President ("SVP").
    United StatesCorporate/Commercial Law
    Sutherland Asbill & Brennan LLP
    Sutherland Asbill & Brennan LLP
  • Article

    The OECD Unified Approach Marches (Stumbles?) Forward

    The OECD "Unified Approach" is marching – or perhaps stumbling – forward. The OECD Secretariat proposed the Unified Approach in October 2019 to address the tax challenges arising from the digitalization of the economy.
    United StatesStrategy
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    District Of Columbia Court Of Appeals Reverses Summary Judgment Granted To Oil Companies In ‘Chainbridge' Litigation

    The DC Court of Appeals held that the Office of Administrative Hearings (OAH) abused its discretion in applying offensive non-mutual collateral estoppel against the DC Office of Tax and Revenue...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Showing 281–300 of 545 results

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