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In this edition: the U.S. Court of Appeals for the Eighth Circuit remands the Medtronic case back to the Tax Court ...

As we settle into the new year, let's take a moment to first consider last year's tax developments and then take a look ahead to what 2023 might have in store for us.

Created by Congress in 1971 as a tax incentive for domestic exporters of U.S.-made goods, the domestic international sales corporation (DISC) remains a viable tool...

Regardless of their political affiliations, presidential administrations and members of Congress share the goal of maintaining U.S. competitiveness on the global market.

On November 8, 2005, in a Special Statewide Election, California voters will decide between two competing prescription drug initiatives, both aimed at reducing the cost of drugs to low and moderate-income uninsured Californians, by authorizing the State to negotiate prescription drug discounts.

By certain measures, December 21 and December 23 were comparable days for the arm's length standard.

Three UK Group Litigation Orders (GLO's), equivalent in many respects to a US class action, were issued in recent weeks by the English High Court in respect of claims against the UK tax authority, the Inland Revenue.

Accounting fair value standards and increased regulatory scrutiny have brought the need for greater transparency and independence and better governance to the way valuation...

The arrival of an information document request ("I.D.R.") for transfer pricing documentation often comes as a surprise to a company.

One key component of the OECD's Pillar One proposal to reallocate taxing rights from producer to consumer nations is the promise that businesses and governments...

On October 8, 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) announced that 136 countries have agreed on a two-pillar framework that would dramatically alter the taxation of multinational enterprises (MNEs).

In most, if not all, outsourcing transactions, suppliers find themselves in a competitive environment. This environment often involves the issuance by a prospective customer to several suppliers of a request for proposal that likely contains business and legal terms and conditions and requires suppliers to indicate their willingness to accept them.

Chancellor Leo E. Strine, Jr., one of the leading judges in the country in the corporate governance area, has become an advocate for judicial restraint and traditional, principle-based review of director conduct by the Delaware courts.

Taxpayers with cost sharing arrangements ("CSAs") can again expect close audit scrutiny—and potential adjustments—related to their treatment of stock-based compensation ("SBC") costs.

Everyone knows that great strategy can’t produce great performance without great planning and execution. Yet companies routinely fall short of the financial results spelled out in their strategic plans. In fact, our research suggests that companies typically deliver less than two-thirds of their strategy’s performance potential and, more importantly, that the causes of this "strategy-to-performance gap" are all but invisible to top management.

Banking groups are under pressure to transform their operating models due to digitalization, changing customer expectations, and heightened ESG requirements. As AI platforms, data governance, and ESG frameworks reshape value creation and risk allocation, the traditional transfer pricing roles and cost-based remuneration models in banking may need fundamental reassessment to reflect evolving business realities.

On December 2, 2017, in the early hours of Saturday morning, the U.S. Senate passed its version of the comprehensive tax reform bill (the "Senate bill").