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The wait is finally over: The Internal Revenue Service Large Business and International (LB&I) Division will start implementing the Large Partnership Compliance (LPC) Program within the next two weeks. The IRS introduced the program last year.

Robert Stack, deputy assistant secretary, International Tax Affairs at the Department of Treasury, recently said that the IRS is working to accept voluntary country-by-country (CbC) reports for the 2016 tax year.

The IRS has renewed its attack on the transfer tax planning technique in which taxpayers make installment sales to intentionally defective grantor trusts

U.S. multinationals expanding their European server infrastructure face critical questions about permanent establishment risks. When do data centers and servers create a taxable presence in Europe...

Are you documenting all your intercompany transactions? If your transactions with a foreign affiliate exceed $10 million, your U.S. company is in danger of an IRS transfer pricing adjustment and a penalty.

In their latest installment of U.S. Tax Review, co-authors James Fuller, Larissa Neuman and Julia Ushakova-Stein examine recent OECD developments, ...

The public is invited to continue to provide comments and suggestions as guidance is written throughout the year.

When US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...

On August 16, 2019, the U.S. Court of Appeals for the Ninth Circuit issued its opinion in the case of Amazon.com, Inc. & Subsidiaries v. Commission of Internal Revenue, finding in favor of the taxpayer.

The IRS challenged Amazon's valuation method, claiming that Luxco's buy-in payment was not arm's length.

Facebook is in a protracted battle with the IRS related to its off-shoring of IP to an Irish affiliate. The IRS issued an administrative summons for the documents, and Facebook has refused to comply.

The IRS recently proposed regulations (REG-141075-09) under Section 83 to clarify and make changes to the current regulations.

FTI Consulting provides valuation reports and expert advice to tax authorities and tax payers for a variety of tax-related valuation needs. We provide deep valuation expertise to tax payers...

Customs valuation determines the value of imported goods for assessing duties and taxes, with tariffs calculated as a percentage of declared entered value. Understanding transaction value methods, assists, royalties, Incoterms, and transfer pricing requirements is critical for multinational companies to avoid costly compliance errors and unexpected tariff liabilities.

On 6 August 2025, the German Federal Ministry of Finance has published a ministerial draft containing several amendments to existing tax regulations.

As a tax practice, how do you bring joy to your clients' lives.

Nikki Dobay and John Ormonde examine the boundaries of Public Law 86-272's protection against state income taxation, analyzing how Massachusetts's Finnigan apportionment rule may conflict with the statute and what this means for combined corporate groups. The discussion extends to state treatment of internet activities, California's regulatory approach, and whether 86-272's protections could reach beyond tangible personal property sales.