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The additional tax payable under the BEAT calculation can be significant.

Foreign direct investment (FDI) in the United States continues to grow, underscoring the country's appeal to global businesses.

In an article published in Insights in 2022, the following comment was made regarding two seemingly never-ending transfer pricing battles being conducted...

The SEC issued the release (the "Adopting Release") formally adopting an amendment (the "Amendment") to Rule 12b-1 under the Investment Company Act of 1940, as amended (the "1940 Act"), prohibiting consideration of a broker-dealer’s efforts in selling shares of an open-end management investment company (a "fund") when determining which broker to use for fund portfolio transactions ("directed brokerage"), as approved at the SEC’s August 18, 2004 o

In this article, we explore the landmark decision in Pepsi Inc v Commissioner of Taxation [2023] FCA 1490 and its implications for the characterisation of royalties for multinational enterprises.

The saga started in 2007, when the IRS began investigating Microsoft's activities from 2004 to 2006.

The District of Columbia Office of Administrative Hearings has issued an order reversing an assessment that was issued against a software company.

As a multinational enterprise setting up operations in the United States, it is imperative for you to understand the complexities of transfer pricing and intercompany transactions.

Multinational groups constantly evolve, grow, and consolidate, and operational facts and circumstances always change. Say a growing company decides to expand internationally. It may choose to incorporate new...

Can the IRS sue a corporation because it believes the company underreported its taxes? You might think the answer is no — the IRS must first propose an adjustment...

The window of opportunity to make large gifts in a tax-efficient manner is scheduled to close at the end of this year.

The Tax Cuts and Jobs Act (TCJA) was hastily enacted and ushered in a sea change to how the U.S. imposes tax on international operations; it was inevitable that litigation...

The current transfer pricing rules for cost sharing arrangements (CSAs) call for certain "buy-ins" (now called PCTs) when one party makes intangible property available for certain research and development purposes.

The purpose of the most recent decision in the Medtronic saga extends and refines the prior analysis of one of five connected controlled transactions within Medtronic's controlled group of multinational medical device producers and suppliers.

The background to the case was the prominent acquisition by BlackRock, in 2009, of the unrelated North American operations of Barclay Global Investors.

Proposed regulations and a proposed revenue procedure recently issued by the Internal Revenue Service would, if finalized in their current form, apply Internal Revenue Code section 83 to the receipt of a partnership interest as compensation for services rendered to the partnership.

Treasury and the IRS issued long-anticipated proposed regulations on Aug. 2 that are designed to curb potentially abusive valuation discounts claimed by taxpayers when interests in family-controlled entities are transferred.