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This Legal Update is the second in a series that Mayer Brown Tax lawyers are publishing on key developments at the national and international levels related to the Organisation for Economic Co-Operation and Development’s ("OECD") Action Plan on Base Erosion and Profit Shifting (the "BEPS Action Plan").

Times are tough. But as multinational businesses wrestle with serious economic pressures, transfer pricing remains central to ultimately balancing their global tax burdens and minimizing tax controversies.

This chapter discusses the basic framework of the United States income tax law applicable to corporations and, to some extent, limited liability companies, partnerships and individuals. It introduces many of the significant U.S. taxing provisions in the form of an overview to assist those interested in doing business in the U.S.

Our Global Tax Policy and Controversy (TPC) Group at A&M Tax is pleased to present the first edition of the A&M Tax Policy Quarterly Outlook (Q4 2025), providing insights for the period from October to December 2025.

With the release last month of a discussion draft on proposed revisions to Chapter IV of its transfer pricing guidelines.

In a 21st century America where new ideas continually create new intangible property, U.S. corporations often desire to contribute their I.P. to a foreign affiliate who then develops and...

As Congress continues to work on stimulus measures, the U.S. economy is threatened by the possibility of a jobless economic recovery.

Mr. Z is a U.S. resident under Code §7701(a)(30) for purposes other than the foreign tax credit. He is a Green Card Holder

Large tax increases are scheduled to take effect in 2013 unless Congress acts, threatening to drastically alter both transfer tax and income tax rules.

Since its enactment in 2002, the Sarbanes-Oxley Act has led to a deluge of studies, reports, and regulations.

This article discusses international tax developments and has been prepared by professionals in the member firms of Deloitte Touche Tohmatsu.

In September, the Internal Revenue Service promulgated comprehensive and important revisions to the regulations regarding the treatment of intercompany services under section 482 of the Internal Revenue Code, along with several key changes to the transfer pricing characterization of intangibles

This article has been prepared by professionals in the member firms of Deloitte Touche Tohmatsu.

The presidential debates put in sharp relief the challenges facing the United States economy regarding rising deficits, underfunded liabilities for Social Security, Medicare, and health care. Outsourcing of jobs has created dislocations and job losses and lessening of employment opportunities throughout the United States and particularly in the economically depressed areas that once were the engines of our economy that fueled our quality of life.

Contents: Hong Kong - Court Rules on Source of Brokerage Company's Income, India - Tribunal Rules on Taxability of Service Fees under India-U.S. Treaty / AAR Rules on Application of India - U.A.E. Treaty, Japan - 2005 Tax Law Changes Affect Inbound Investment / New Law May Prohibit Japanese Branch Operations of Foreign Companies, Macau - Government Restricts Activities of Offshore Companies, Philippines - Corporate Tax and VAT Changes Enacted, Taiwan - MOF Issues Rulings on Taxation of Forei

As companies finalize their Q2 2025 reporting, tax departments are once again navigating a shifting landscape of legislative and regulatory change. The centerpiece of this quarter's developments was the advancement...

Москва, 3 февраля 2020 года — Лидия Чарикова присоединилась к российской налоговой и там