545 results found

On March 16, 2018, the OECD/G20 Inclusive Framework on BEPS issued its Interim Report on the Tax Challenges Arising from Digitalization.

For many of our clients, this is a particularly appropriate time to review one's estate plan. In most circumstances, the passage of several years alone is a sufficient basis for commencing such a review based upon changes in family and financial circumstances.

July 24, 2018, marked a significant, although potentially short-lived, victory for the IRS, as a panel of the US Court of Appeals for the Ninth Circuit reversed by 2 votes to 1, the full US Tax Court's unanimous opinion...

On August 16, 2019, the Ninth Circuit upheld Amazon's cost-sharing arrangement and valuation of its intangible assets, affirming the Tax Court's 2017 decision

Although the negotiation process has slowed due the Covid-19 pandemic, demand for bilateral advance pricing agreements (APAs) between India and the US continues to ...

Yesterday, the IRS issued proposed regulations under Code §409A. As discussed in our prior Cooley Alerts, §409A covers a wide range of nonqualified deferred compensation plans and arrangements and imposes a number of strict requirements that such plans and arrangements must satisfy in order for participants to avoid immediate taxation, an additional 20% tax, and interest on underpayments of tax.

One group of six professors first notes its agreement with the arguments advanced by the government in its opening brief.

The Israeli District Court decision in Hexadite Ltd. v. Israel Tax Authority provides important lessons on transfer pricing, valuation of intangibles, and post-acquisition business-model changes.

Taxpayers that have relied on cost sharing arrangements under the 1996 regulations must consider whether and how such reliance will be viable in the future under the new regulations.

Our June 2017 blog posts are available on insidesalt.com, or read each article by clicking on the titles below.

The Court of Appeal's ("CA") ruling in April 2024 in the case of BlackRock Holdco 5 LLC v HMRC ("BlackRock")1 considered the deductibility of interest...

India possesses a dynamic and growing economy, as its government portrays as business friendly, and it actively encourages continued foreign direct investment.

Our International Tax Group analyzes the report on the IRS's Advance Pricing and Mutual Agreement Program and identifies important insights and trends for advance pricing agreements.

The digital era has brought immense technological change in all aspects of life and society with the rise of the internet, mobile devices, cloud computing and more. GenAI has now emerged to shape

The Mutual Agreement Procedure ("MAP") is a useful dispute resolution mechanism for multinational companies facing a transfer pricing...

The report discloses that 98 complete APA applications were filed with the APMA Program in 2016, indicating a significant decrease from the 183 complete applications filed in 2015.

On Feb. 19, 2024, the Organization for Economic Cooperation and Development (OECD) amended its transfer pricing guidelines to include "Amount B," a standardized approach...