545 results found

The limitation of interest deductibility to approximately 30% of E.B.I.T.D.A. (earnings before interest, tax, depreciation, and amortization) introduced in amended Code §163(j) has focused the attention of U.S. corporations ...

In Canada, taxpayers must file CRA Form T106 to disclose certain non-arm's length transactions with non-residents. The United States does not have a single consolidated disclosure form equivalent to T106.

A recent federal appeals court ruling giving the IRS access to data in a transfer pricing dispute has the potential to put multinational companies on a collision course with stringent European Union privacy laws.

International tax reform in 2026 introduced structural changes that affect how global income is classified, included, deducted, and limited.

Serving as a roadmap for how the Internal Revenue Service intends to conduct transfer pricing examinations, the recently released Transfer Pricing Examination Process ...

The new federal transfer tax law provides unprecedented planning opportunities for 2011 and 2012.

Despite adding personnel and making a concerted effort to speed up the advance pricing agreement process, the Advance Pricing and Mutual Agreement Program (APMA) faces challenges...

Yesterday, the Trump Administration, the House Committee on Ways and Means, and the Senate Finance Committee proposed a "unified framework" for tax reform.

One message stood out during our Tax Symposium 2026 session, Tax controversy: What’s hot and what’s not: The Internal Revenue Service (IRS) is becoming more strategic...

First came last week's surprising news that current highway funding levels can carry the nation's infrastructure through next summer—well beyond the October 29 expiration of the current authorization for highway spending.

Announcement 2010-30 provides additional details and clarifications regarding the type of information taxpayers will have to provide, but assumes that the IRS has the authority to require a taxpayer to provide information on uncertain tax positions.

The Internal Revenue Service (IRS) is facing a steep workforce reduction that threatens its capacity to assist businesses just as many confront growing uncertainty around global trade...

Recent events highlight increased activities by both federal and state enforcement agencies addressed at historical Medicaid drug pricing strategies, with a growing focus on programmatic changes which could help control future Medicaid drug costs.

The One Big Beautiful Bill Act (OBBBA) has reshaped tax incentives for wineries, expanding opportunities for R&D expense deductions, production property depreciation, and energy credits. Understanding how these changes interact with winery operations—from fermentation systems to facility upgrades—can significantly impact cash flow and investment returns. This framework helps wineries align tax planning with operational decisions to maximize available benefits.

An authorized generic (AG) is a pharmaceutical product that was originally marketed and sold by a brand company, but is relabeled and marketed under a generic product name.

On September 7, 2021, the US Treasury published final regulations1 that, among other things, prohibit Internal Revenue Service (IRS) contractors from questioning witnesses during summons interviews.

Purchase options within retail leases are significant issues and are often highly negotiated. Because landlords often provide prospective tenants with the initial draft of a lease, landlords can try to favorably dictate the terms of purchase options in its initial lease draft.