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In 2022, we foresee several trends and developments that will converge to substantially impact tax controversies in the United States.

The IRS has made it clear publicly that it will increase efforts to identify tax fraud and underpayments by individuals and businesses with annual income of more than $400,000.

In 2000, Evanston Hospital and Glenbrook Hospital merged with Highland Park Hospital and merged the combined entity into Evanston Northwestern Healthcare Corporation ("ENH"). The total value of the merger was in excess of $200 million.

Newly adopted rules will require each investment company and investment adviser registered with the Commission to implement policies and procedures designed to prevent violation of the federal securities laws, and designate a chief compliance officer "CCO" to administer them. The policies and procedures and CCO must be in place by October 5, 2004.

The lack of consensus amongst O.E.C.D. Member States on the Discussion Draft may foreshadow difficult double-tax cases between competent authorities.

On September 29, 2005, the IRS issued its long-awaited proposed regulations under Code Section 409A (the "Proposed Regulations").

This month finds the arm's length principle continuing to operate among O.E.C.D. Member States and the broader inclusive framework working toward international tax reform of the digitized economy.

In this edition: the OECD releases discussion draft on hard-to-value intangibles, Australia issues risk framework for evaluating intercompany loans, recent transfer pricing developments in India, ...

In this edition: U.S. tax court rules in favor of Amazon, U.S. tax reform and the effects on transfer pricing, OECD releases toolkit for identifying financial data in developing countries...

This article highlights significant developments affecting the healthcare industry.

Given the projected loss in tax revenue in 2020, and beyond, due to the COVID-19 pandemic, states are looking for ways to stop the bleeding, including through typical methods (e.g., raising tobacco, fuel and other excise taxes) ...

In transfer pricing analysis, the determination of the entity or entities within a multinational enterprise that are entitled to share in the returns derived by the group from exploiting...

Earlier this month, AdvancePCS, a pharmacy benefits manager (PBM) acquired by Caremark last year, agreed to a $137.5 million fine and a five-year injunction and settlement agreement with the U.S. Department of Justice and the U.S. Attorney’s Office for the Eastern District of Pennsylvania. The settlement resolved an extensive investigation into allegations associated with the PBM’s operational practices.

On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under section 951(a)(2)(B).

The current international tax system was established on principles dating back to the first half of the 19th century, when the internet did not exist and the economy mostly consisted of brick-and-mortar stores.

In this edition: The OECD unveiled the latest proposals to address the tax challenges of the digitalization of the economy; the IRS updated its tax statistics database with Statistic of Income data for tax year 2016;

The Organisation for Economic Co-operation and Development has released its "Country-by-Country Reporting Implementation Package".