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There is an age-old adage that "bad facts make bad law", which in the world of tax jurisprudence has proven to be the case time and time again.

Determining the locus of ownership of intangible property related to the development of new products and services is one of the principal challenges that tax managers in multinational enterprises (MNEs) face on an ongoing basis. Tax managers must balance non-tax corporate objectives, tax efficiency, tax risk management, and financial reporting considerations.

Weather derivatives are starting to make an appearance in the project finance market. Energy finance professionals need to be familiar with these risk mitigation tools and the creative ways that they can be used.

The new Technology Transfer Block Exemption ("the TTBE"), which entered into force on May 1, presents the final step in the Commission’s program to overhaul Article 81 EC. Compared to its predecessor, generally referred to as "the last dinosaur," the TTBE introduces a considerable degree of flexibility into the framework underlying the competition law analysis of technology licensing agreements.

A number of controversial issues remain unresolved with respect to the interpretation of the German thin capitalization rules. One issue, in particular, concerns third party debt with shareholder recourse.

The dust is beginning to settle on the effect and fate of SAFE Circular 11 and Circular 29, at least for the time being. On October 21, 2005, SAFE issued the long awaited new circular on "Relevant Issues Concerning Foreign Exchange Control on Domestic Residents' Corporate Financing and Roundtrip Investment Through Offshore Special Purpose Vehicles"

This outline is a selective and evolving review of the history of the modern federal estate tax.

At the end of 2019, most U.S. tax practitioners expected that the most important U.S. tax developments in 2020 would cluster around two topics.

Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th president of the United States.

The tax landscape for technology companies has shifted dramatically over the past five years. Beginning with the 2017 Tax Cuts and Jobs Act ("TCJA"), U.S. tax policy has taken a notable...

At the end of its 2023 term, the Supreme Court issued two opinions that will drastically change how taxpayers can challenge Department of Treasury (Treasury)...

As promised before the end of 2024, Treasury and the I.R.S. outlined their approach to the codification of Amount B, a component of the O.E.C.D. Pillar One approach1 ("O.E.C.D. guidance")...

On February 27, 2008, the Treasury Department (Treasury) and the Internal Revenue Service (the Service) released proposed regulations that provide comprehensive guidance on the treatment of contract manufacturing arrangements under the foreign base company sales income (FBCSI) rules of subpart F.

In February 2020, the Organization for Economic Cooperation and Development ("OECD") released Transfer Pricing Guidance on Financial Transactions ("Guidance").

As the global tax controversy landscape evolves and becomes more polarized, marked by cross-border audits and mounting pressure on revenue authorities to collect tax, Jones Day partners examine how geopolitical pressure and rising revenue demands are reshaping tax disputes worldwide. The discussion highlights the complexity of navigating uncertain tax environments where authorities are increasingly sharing information across borders and deploying sophisticated anti-abuse provisions.

We are delighted to present the Fall Edition of our A&M Tax & Customs Newsletter. This edition offers timely insights and key analyses of the most significant tax and customs regulatory developments from the past quarter...

On April 20 2005, after almost a decade of effort by both congressional houses and a multitude of lobbyists, the president signed the Bankruptcy Abuse Prevention and Consumer Protection Act 2005.