Mondaq USA: Tax > Transfer Pricing
Grant Thornton LLP
In a recently released private letter ruling (PLR 201714028), the IRS Office of Chief Counsel determined that liabilities transferred by a taxpayer to a partnership constituted qualified liabilities...
Ruchelman PLLC
In finding for the taxpayer in a recent transfer pricing decision, the U.S. Tax Court followed its own determination in Veritas in valuing a buy-in payment made as compensation...
Grant Thornton LLP
The IRS has appealed its loss on in the Tax Court in Medtronic, Inc. v. Commissioner to the Eighth Circuit Court of Appeals.
Ruchelman PLLC
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...
Jones Day
The IRS challenged Amazon's valuation method, claiming that Luxco's buy-in payment was not arm's length.
Reed Smith
On November 9, the Multistate Tax Commission's Transfer Pricing Committee met to continue its effort to develop and implement a comprehensive transfer pricing program, through which states can identify and remedy allegedly distortive pricing with respect to intercompany transactions.
McDermott Will & Emery
The IRS has released statistics for the 2010 to 2014 tax years relating to Schedule UTP filings, showing that there were 6,320 uncertain tax positions reported in 2014.
Grant Thornton LLP
The IRS released a private letter ruling that held that the acquisition of substantially all the assets of a transferred corporation results in the termination of the associated gain recognition agreement under Section 367.
Grant Thornton LLP
The IRS has added and modified several international guidance projects in the 2016‒2017 Priority Guidance Plan.
Dentons
The Internal Revenue Service in Ecuador established regulations in regards to indirect expenses in order to apply a deductibility threshold for these expenses when calculating the Income Tax for Ecuadorian taxpayers...
Saul Ewing LLP
I've written before about the new proposed Treasury Regulations under Section 2704 of the Internal Revenue Code.
McDermott Will & Emery
In Altera Corp v Commissioner, 145 TC No. 3, the Tax Court, in a unanimous reviewed opinion, held that regulations under Section 482 requiring parties to a QCSA to include stock-based compensation...
Grant Thornton LLP
The DC Court of Appeals held that the Office of Administrative Hearings (OAH) abused its discretion in applying offensive non-mutual collateral estoppel against the DC Office of Tax and Revenue...
Grant Thornton LLP
Treasury and the IRS issued long-anticipated proposed regulations on Aug. 2 that are designed to curb potentially abusive valuation discounts claimed by taxpayers when interests in family-controlled entities are transferred.
Reed Smith
The MTC has adopted a new moniker for its transfer pricing initiative.
Thompson Coburn LLP
As you may have heard, the IRS recently issued proposed regulations that will impact the valuation of closely-held, family entities for gift, estate and generation-skipping tax purposes.
McDermott Will & Emery
The public is invited to continue to provide comments and suggestions as guidance is written throughout the year.
McDermott Will & Emery
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.
Baker Newman Noyes
In an era of globalization and continued growth of international trade, inter-company pricing has become an everyday necessity for many businesses.
Baker Newman Noyes
Shakespeare, through Polonius, tells us "Neither a borrower nor a lender be; for loan oft loses both itself and friend…" Proposed tax rules suggest that it will also soon lose favorable tax treatment.
Latest Video
Most Popular Recent Articles
Ruchelman PLLC
In finding for the taxpayer in a recent transfer pricing decision, the U.S. Tax Court followed its own determination in Veritas in valuing a buy-in payment made as compensation...
Grant Thornton LLP
In a recently released private letter ruling (PLR 201714028), the IRS Office of Chief Counsel determined that liabilities transferred by a taxpayer to a partnership constituted qualified liabilities...
Grant Thornton LLP
The IRS released a private letter ruling that held that the acquisition of substantially all the assets of a transferred corporation results in the termination of the associated gain recognition agreement under Section 367.
Ruchelman PLLC
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...
Grant Thornton LLP
The IRS has appealed its loss on in the Tax Court in Medtronic, Inc. v. Commissioner to the Eighth Circuit Court of Appeals.
Jones Day
The IRS challenged Amazon's valuation method, claiming that Luxco's buy-in payment was not arm's length.
McDermott Will & Emery
The public is invited to continue to provide comments and suggestions as guidance is written throughout the year.
Grant Thornton LLP
Treasury and the IRS issued long-anticipated proposed regulations on Aug. 2 that are designed to curb potentially abusive valuation discounts claimed by taxpayers when interests in family-controlled entities are transferred.
McDermott Will & Emery
The IRS has released statistics for the 2010 to 2014 tax years relating to Schedule UTP filings, showing that there were 6,320 uncertain tax positions reported in 2014.
Reinhart Boerner Van Deuren S.C.
Determining the arm's length transfer price of intercompany transactions has created some of the most resource consuming controversies in taxation and may result in a transfer pricing penalty.
Article Search Using Filters
Related Topics
Mondaq Advice Center (MACs)
Popular Authors
Popular Contributors
Up-coming Events Search
Tools
Font Size:
Translation
Channels
Mondaq on Twitter
Partners
In association with