545 results found

Late last year, the Internal Revenue Service's (IRS's) Large Business and International (LB&I) division announced that it would restructure its organization.

From time to time, we’ll be using this space to discuss recurring Massachusetts state tax issues were seeing at audit and on appeal.

In 1992 the Court of Appeals for the Federal Circuit in Nissho Iwai American Corp. v. United States established the First Sale Rule by stating that "sale for export" in the valuation...

The German competition authority (Bundeskartellamt) has found that seven insurance companies participated in a price-fixing cartel and imposed fines totaling more than €20 million against the companies and their directors.

On December 13, 2018, the US Internal Revenue Service released an initial set of proposed regulations addressing a number of open issues under the Base Erosion Anti-Abuse Tax (BEAT) rules.

Deputy Executive Director Greg Matson (a nice guy at heart) announced this week that the Multistate Tax Commission (MTC) has hired its first transfer pricing training consultant and is scheduled to begin training state auditors.

It is possible that Blondie was speaking from the perspective of the IRS in its hit song "One Way or Another"...

The U.S. Bankruptcy Court for the District of Delaware recently ruled that a tax-sharing agreement created a debtor-creditor relationship between parties to the agreement.

On May 30, 2012, U.S. Customs and Border Protection (CBP) announced the revocation of an administrative ruling (Headquarters Ruling Letter (HRL) 547654, dated November 8, 2001).

The French government estimates that the DST would raise approximately 500 million Euros per year.

Clark Armitage offers his insights in Roundtable: Transfer Pricing for the February 2023 issue of Financier Worldwide Magazine.

The Organisation for Economic Co-operation and Development (OECD) has pushed for additional levels of transparency in the context of the Base Erosion and Profit Shifting ("BEPS")* project.

Loyens & Loeff New York regularly posts ‘Snippets' on a range of EU tax and legal topics. This is our latest Snippet on the upcoming public Country-by-Country reporting ("Public CbCR") obligations in Europe.

A discussion on tax-advantaged transfer pricing for intellectual property.

How are multinational enterprises adapting their transfer pricing (TP) strategies in response to the OECD’s Pillar One and Pillar Two implementations, particularly Amount B and the global minimum tax? What major changes do you anticipate in global TP guidance through 2026?

Clark Armitage offers insights in Indepth Feature: Global Tax for the October 2023 issue of Financier Worldwide Magazine.

Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations: (i) the reduction of European taxes ...

The IRS is requesting that the Court of Appeals for the Ninth Circuit remand the U.S. Tax Court's decision.