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NYSE Files Change of Interpretive Position on Discretionary Voting with Respect to Fund Advisory Contract Proposals; FFIEC Releases 2004 HMDA Data; SEC Approves NASD’s Revised Definition of Branch Office; FRB, FDIC and OCC Announce Implementation of Online Call Report System; Also Propose Changes to Call Report; SEC Adopts Katrina-Related Measures

During a 2019 Tax Executives Institute conference in Washington, D.C., the Commissioner of the U.S. Internal Revenue Service (IRS), ...

On June 21, 2018, the OECD released long-awaited final guidance on the appropriate application of the Transactional Profit Split Method and on Implementing the OECD's guidance on Hard to Value Intangibles.

Today's historically low interest rates and depressed asset values make this an excellent time to engage in various estate planning techniques. Minimizing gift and estate tax when transferring assets is of primary importance in this uncertain time.

The New York City Tax Appeals Tribunal recently issued what may be the most significant taxpayer victory in New York to date on when the New York tax authorities may forcibly combine a corporate taxpayer with an affiliated intangibles holding company.

On June 6, 2012, the Organisation for Economic Co-operation and Development (OECD) released a discussion draft on potentially updating the provisions of Article 6 of the OECD Transfer Pricing Guidelines (Guidelines).

Perhaps the most innovative financial product of the 1990s was the credit derivative contract. Credit derivative contracts allow parties to transfer and speculate on the creditworthiness of a taxpayer. The contracts usually take the form of a credit derivative swap ("CDS") using an ISDA master agreement.

In response to the increase in outsourcing activities by firms in the financial sector, regulators at an international, European and UK level have been considering new regulations to control those activities. This article tracks the recent developments in the proposed regulations.

On January 31, 2020, the OECD/G20 Inclusive Framework on BEPS released an update on its efforts to effect major changes in international tax rules.

The taxation of transactions involving intangible assets (either by licence of use or directly by their transmission) is possibly the OECD's biggest concern on transfer pricing and international tax at the moment.

As the first Monday in October approaches, the business community should be paying more attention than usual to the start of the 2005-2006 Supreme Court term.

Recently-issued proposed regulations under Section 409A of the Internal Revenue Code provide some guidance and flexibility for public companies in setting the exercise prices for their stock options, base prices for stock appreciation rights ("SARs"), and values for other stock-based compensation.

In Altera Corp v Commissioner, 145 TC No. 3, the Tax Court, in a unanimous reviewed opinion, held that regulations under Section 482 requiring parties to a QCSA to include stock-based compensation...

When a Canadian or U.S.-based multinational finds itself under audit, the taxpayer and the tax authority are often at odds over what documentation is subject to disclosure...

On June 7, 2019, in Altera Corp. v. Commissioner[1], a reconstituted panel of the U.S. Court of Appeals for the Ninth Circuit issued a new opinion upholding the validity of a Treasury Department

Do the transfer pricing rules apply to your transaction? If you are asking that question because adjusting transfer prices could reduce your tax bill, the answer likely is "yes."

In March 2013, 3M filed a petition with the U.S. Tax Court challenging the Internal Revenue Service's determination that $23.6 million in additional royalty income should be allocated to 3M's U.S. headquarters from its Brazilian subsidiary.