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  • Article

    Global Tax Guide To Doing Business In... 2019

    Globalization has diminished the barriers encountered by multinational businesses.
    United StatesTax
    Dentons
    Dentons
  • Article

    Government Drops Statute Of Limitations Defense In McKesson Cost-sharing Challenge

    The US Department of Treasury defends its authority to regulate stock-based compensation in cost-sharing arrangements under IRC § 482, arguing the regulations fall within statutory bounds and are necessary to ensure arm's-length results between related parties. The government's response to McKesson Corporation's summary judgment motion addresses challenges based on the Loper Bright decision and notably abandons its six-year statute of limitations defense.
    United StatesTax
    McDermott Will & Schulte
    McDermott Will & Schulte
Article

IRS Announces Transfer Pricing Campaign Targeted At Mid-Market Multinational Companies

On January 31, 2017, the IRS announced that its Large Business and International ("LB&I") division will focus on issue-based examinations.
United StatesTax
Duff and Phelps
Duff and Phelps
  • Article

    IRS Finalizes Inventory Sale Sourcing Regulations

    On September 29, 2020, Treasury and the IRS issued final regulations on how to source gain from inventory sales
    United StatesTax
    Hogan Lovells Cadwalader
    Hogan Lovells Cadwalader
  • Article

    IRS Ramps Up Enforcement Efforts; Focuses On Foreign-Owned And 'Mega' Corporations

    Following their recent announcement regarding new partnership and global high wealth enforcement initiatives,1 the Internal Revenue Service (IRS) on Oct. 20...
    United StatesTax
    Greenberg Traurig
    Greenberg Traurig
  • Article

    LB&I Keeps Transfer Pricing Examination Process Current

    Review of the applicable guidance for these approaches can assist with taxpayer's own assessment of risk and documentation planning for the current year.
    United StatesTax
    Duff and Phelps
    Duff and Phelps
  • Article

    ACRA Fails to Prove State Law False Advertising Claim

    The U.S. Court of Appeals for the Ninth Circuit upheld a district court’s grant of summary judgment in a shrink-wrap license case, finding the plaintiff had not produced sufficient evidence to raise a triable issue of fact.
    United StatesIntellectual Property
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    TAX TAKE: The Rubber Has Met The Road: Senate Democrats Announce $3.5 Trillion Package

    Last week Senate Democrats, led by Senate Majority Leader Charles Schumer (D-NY), announced an agreement on a $3.5 trillion package that includes President Biden's spending priorities...
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Transfer Pricing Times – August 2019

    In this edition of Transfer Pricing Times, we present the latest and most relevant transfer pricing issues and developments from around the globe.
    GlobalTax
    Duff and Phelps
    Duff and Phelps
  • Article

    The Proposed Revision Of Chapter VII Of The OECD Transfer Pricing Guidelines: What Changes For Intra-Group Services?

    The OECD's proposed revision of Chapter VII of the Transfer Pricing Guidelines aims to clarify the framework for intra-group services, with the benefit test emerging as the central analytical principle.
    United StatesTax
    NERA
    NERA
  • Article

    Trade, Tariffs, And Tax Effects: Deal-Maker Considerations For Diligence And Structuring

    Riveron's M&A Tax and Transaction Services experts have observed the latest changes and evolving trends related to US trade and tariff policies and have participated in several discussions on the potential impacts.
    United StatesInternational Law
    Riveron
    Riveron
  • Article

    Dispute Between IRS And Medtronic Over IP Valuation Heading Back To Court

    The Medtronic case is slated to head back to court in April of 2020 in accordance with an order from the tax court.
    United StatesTax
    Duff and Phelps
    Duff and Phelps
  • Article

    OECD Releases Program For Reaching Consensus On Taxation Of Digital Economy

    The tax challenges of the digitalization of the economy were identified as a primary area of focus in the 2015 BEPS Action 1 Report.
    United StatesTax
    Duff and Phelps
    Duff and Phelps
  • Article

    Proposed New IRS Rules For Valuing Interest In Family-Controlled Entities May Curb Discounts For Estate, Gift And Generation-Skipping Tax Purposes

    The new rules are in proposed form and are not effective until issued in final form.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    September 15th Deadline For Taxpayer Participation In North Carolina Transfer Pricing Resolution Initiative

    On August 1, 2020, North Carolina announced its first formal voluntary disclosure initiative aimed specifically at resolving corporate transfer pricing liabilities.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Tax Efficient Repatriation Methods For U.S. Subsidiaries

    As the end of the year nears, a U.S. subsidiary may try to repatriate cash to its foreign parent. Repatriation may occur in several different methods with each having advantages and disadvantages.
    United StatesTax
    Reinhart, Boerner, Van Deuren SC
    Reinhart, Boerner, Van Deuren SC
  • Article

    Treasury Department Issues Highly Anticipated Proposals Limiting Valuation Discounts

    On August 2, 2016, the U.S. Department of the Treasury released proposed regulations under Code Sections 2701 and 2704.
    United StatesTax
    Baker Newman Noyes
    Baker Newman Noyes
  • Article

    With A New Name, MTC Transfer Pricing Program Moves Forward

    The MTC has adopted a new moniker for its transfer pricing initiative.
    United StatesTax
    Reed Smith
    Reed Smith
  • Article

    United Nations Issues Draft Guidance On Financial Transactions, Profit Splits And Risk Assessment

    It is Duff & Phelps' understanding that the OECD's draft is also in the process of being finalized and will likely be made available this year.
    GlobalTax
    Duff and Phelps
    Duff and Phelps
  • Article

    Will the Bankruptcy Code Protect You From Certain Taxes?

    Several judicial decisions in the past year have renewed the debate about when the transfer of property during a Chapter 11 bankruptcy is exempt from state and local taxes. Although the debate focuses on a single provision of the Bankruptcy Code, the answer may determine tax liabilities in the hundreds of thousands if not millions of dollars.
    United StatesAccounting and Audit
    Foley & Lardner LLP
    Foley & Lardner LLP
  • Showing 61–80 of 545 results

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