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  • Article

    Pillar Two And The “Side-By-Side” Agreement: A Guide For The Perplexed*

    H. David Rosenbloom examines the complexities of Pillar Two and the "Side-by-Side" Agreement in international tax law, providing clarity on these intricate mechanisms. This analysis explores the technical framework and implications of these global tax reform measures for multinational enterprises and tax practitioners.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    The OBBBA International Tax Provisions

    H. David Rosenbloom co-authored an article examining the international tax provisions of the OBBBA legislation, providing a comprehensive nutshell explanation of these complex regulatory measures. The piece offers detailed analysis of how these provisions impact cross-border taxation and international tax planning strategies.
    United StatesTax
    Caplin & Drysdale, Chartered
Caplin & Drysdale, Chartered
  • Article

    US Banking Agencies Issue Interagency Guidance On Funds Transfer Pricing Related To Funding And Contingent Liquidity Risks

    The guidance notes that an institution's FTP framework should be adequately tailored to its size, complexity, business activities and overall risk profile.
    United StatesFinance and Banking
    A&O Shearman
    A&O Shearman
  • Article

    Is ICAP A Viable Alternative To APAs?

    Clark Armitage, David Rosenbloom, and Arjun Ghosh co-wrote the article "Is ICAP a Viable Alternative to APAs?" for IBFD International Transfer Pricing Journal 2023 in Volume 30, No. 5.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Microsoft Ruling Highlights Need To Document Biz Decisions

    Microsoft Ruling Highlights Need To Document Biz Decisions.
    United StatesTax
    Ropes & Gray LLP
    Ropes & Gray LLP
  • Article

    Proposed Regulations Aim To Eliminate Many Valuation Discounts

    The IRS has published proposed regulations that, when issued in final form, will se-verely curtail the use of valuation discounts in order to transfer interests in family-controlled entities...
    United StatesTax
    Milbank
    Milbank
  • Video

    The Trouble With Transfer Pricing For Foreign Parents And US Subsidiaries (Video Content)

    US fashion companies owned by foreign parent companies routinely encounter transfer pricing issues.
    United StatesTax
    ArentFox Schiff
    ArentFox Schiff
  • Article

    Complaint About Foreign Tax Violations Sunk Under SOX

    On February 12, 2014, the Fifth Circuit in Villanueva v. U.S. Department of Labor held that an employee did not engage in protected activity under SOX when he reported alleged violations of Columbian tax laws to U.S. executives at his employer.
    United StatesEmployment and HR
    Orrick
    Orrick
  • Article

    The Cameco And Glencore Transfer Pricing Cases – Comments On The Common Complications In Commodities Commerce Controversy

    Two transfer pricing cases, in Australia and in Canada, address arm's length transfer pricing methodology for mined minerals during a period of steep increases in spot prices. In each case
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    Alabama Joins Transfer Pricing Advisory Group To Develop New Service For The Multistate Tax Commission

    Alabama has joined the District of Columbia, Florida, Georgia, Hawaii, Iowa, Kentucky, New Jersey, and North Carolina.
    United StatesTax
    Bradley Arant Boult Cummings LLP
    Bradley Arant Boult Cummings LLP
  • Podcast

    Clark Armitage Discusses Cross-Border Transfer Pricing Disputes (Podcast)

    The "GILTI Conscience" podcast team, led by Skadden partners David Farhat and Nate Carden, hosted Clark Armitage of Caplin & Drysdale for an in-depth conversation...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Podcast

    Clark Armitage Discusses U.S. Tax Disputes Trends (Podcast)

    What are current trends in US tax disputes? How can you reduce litigation risk? What is the Supreme Court likely to make of Moore, a case that could call into question large swathes of the US tax system?
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Contract Manufacturing: Considerations For Transfer Pricing In France

    In the Bloomberg 2024 Transfer Pricing Forum, Senior Managing Director Emmanuel Llinares and Delsol Avocats Partner Julien Monsenego explain considerations for the transfer pricing of contract manufacturing
    United StatesTax
    NERA
    NERA
  • Article

    Do You Need Transfer Pricing Analysis?

    A transfer pricing study or analysis helps companies decide how to price transactions between related parties in different tax jurisdictions.
    United StatesTax
    Kaufman Rossin
    Kaufman Rossin
  • Article

    IRS Issues IPU On Corporate Inversions

    On June 7, 2016 , the IRS released an LB&I International Practice Unit, providing high-level guidance to IRS field examiners on the application of the anti-inversion rules of Internal Revenue Code section 7874.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    Planning For Transfer Pricing: Brand Management Center For Consumer Articles In Switzerland

    The relocation of old, well-established brands in times of BEPS can be mastered by a careful dissection of intellectual property into various usage rights.
    United StatesTax
    NERA
    NERA
  • Article

    Successful Approaches To Intellectual Property Valuation

    A&M Tax Managing Director Dan Peters moderated a panel at TP Minds Americas on February 9th. Dan was joined by Sheetal Kumar of Baker Hughes, Tatyana Pashova...
    United StatesTax
    Alvarez & Marsal
    Alvarez & Marsal
  • Article

    Thoughts On The Amount B Framework: Considerations For Contributions Within And Beyond The Baseline Scope

    On 19 February 2024, the OECD/G20 Inclusive Framework on BEPS released its final report on Amount B of Pillar One, "Special Considerations for Baseline Distribution Activities."
    United StatesTax
    NERA
    NERA
  • Article

    Treasury To Publish Proposed Regulations Regarding Valuing Interests In Corporations And Partnerships For Gift And Estate Tax Purposes

    The IRS has just proposed regulations regarding the valuation of interests in corporations and partnerships for federal transfer tax purposes.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    EU Clarifies Exemption of Technology Transfers from Antitrust Law

    Last spring, the Commission of the European Union issued new regulations and guidelines on the application of EU antitrust law to technology transfer agreements (Commission Regulation No. 772/2004 of 27 April 2004).
    United StatesAntitrust/Competition Law
    Robinson Bradshaw & Hinson
    Robinson Bradshaw & Hinson
  • Showing 1–20 of 544 results

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