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The YA Global case has drawn widespread attention due to the U.S. tax implications for foreign investment entities investing in U.S. securities or making use of a U.S. investment manager.

For many years, the U.S. government has been concerned about U.S. businesses reducing or deferring U.S. income tax liabilities through the use of foreign corporations.

The United States Department of Defense ("DOD") is in the process of determining which now-active military facilities it intends to recommend for inclusion in the next base realignment and closure ("BRAC") round. The President and Congress are scheduled to approve or disapprove DOD’s recommendations at the end of 2005.

Transfer pricing has to do with the allocation of income among parties controlled by the same persons (controlled parties) that engage in transactions with each other

Transfer pricing complexities emerge as artificial intelligence systems increasingly rely on vast training datasets, raising critical questions about how multinational corporations should value and allocate these intangible assets across jurisdictions. The intersection of AI development and international tax law presents novel challenges for determining arm's length pricing when data crosses borders within corporate structures.

The U.S. government may have avoided a challenge to a controversial section 78 regulation by issuing the taxpayer a refund. In Kyocera, 1 the taxpayer challenged the validity of a regulation...

On January 5, 2026, the OECD Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS) released the highly anticipated Side-by-Side (SbS) package.

On January 12, 2018, the U.S. IRS Large Business and International ("LB&I") Division issued several new directives establishing procedural changes aimed at enabling the IRS to manage resources in transfer pricing audits.

As all multinationals are discovering, domestic implementation of the recommendations set out in the BEPS final reports from 2015 have the potential to significantly impact effective tax rate planning.

On December 22, 2017, President Donald Trump signed the Tax Cuts and Jobs Act (the "Act") which introduced sweeping changes to the U.S. tax code.

In this Ropes & Gray podcast, Ellen Gilley, an associate in the tax controversy group, is joined by Kat Gregor, a partner in the tax group and co-founder of the tax controversy group,...

The IRS has intensified scrutiny of partnership basis-shifting transactions that manipulate inside and outside basis rules to generate tax savings. While recent regulations were withdrawn under the Trump Administration, the agency maintains its position through Rev. Rul. 2024-14, which identifies three transaction types that fail the economic substance doctrine.

Greenberg Traurig shareholder Breen Schiller has submitted formal comments and testimony to Illinois tax authorities regarding proposed amendments to regulations governing addbacks for interest and intangible expenses in transactions with 80/20 companies. The comments address concerns about conduit exception narrowing, limitations on the "unreasonable" standard, and reliance on private letter rulings that may create administrability challenges for Illinois businesses.

The comparable profit method is a standard method for transfer pricing, particularly when the intracompany transactions are entirely between two related parties and third-party prices...

Congratulations. Your Israeli start-up is doing well enough for you to consider expanding operations to the U.S. market. Now what? The list of things to think of is endless...

In May, the I.R.S. announced a settlement offer for partnerships involved in disputes concerning "syndicated conservation easements." The key features of the offer include a 10% penalty for gross valuation misstatement, instead of a 40% penalty, and no upfront payment required.

The legal, economic and financial reforms undertaken by the Indian government since the early 1990’s have resulted in substantial and rapid growth of the Indian economy and led to the integration of India into the global economy. While reform efforts stalled somewhat during the weak coalition governments of the mid-1990’s, following the 1999 parliamentary elections, the Bharatiya Janata Party-led government launched a second round of economic reforms, which included major privatization, deregula

The U.S. Treasury and IRS have issued proposed regulations addressing a new category of income excluded from deduction eligible income under section 250(b)(3)(A)(i)(VII), which was introduced by the One Big Beautiful Bill Act. These regulations clarify how income from sales of intangible property and certain depreciable assets will be treated under the foreign-derived deduction eligible income regime, with significant implications for software transactions and related party transfers.