Mondaq USA: Tax > Transfer Pricing
Dentons
Glenn DeSouza, transfer pricing leader in Dentons' Shanghai office, examines China's transfer pricing regime as outlined in three bulletins, the most recent of which was issued in March.
Duff and Phelps
On January 31, 2017, the IRS announced that its Large Business and International ("LB&I") division will focus on issue-based examinations.
Duff and Phelps
The report discloses that 98 complete APA applications were filed with the APMA Program in 2016, indicating a significant decrease from the 183 complete applications filed in 2015.
McDermott Will & Emery
Our June 2017 blog posts are available on insidesalt.com, or read each article by clicking on the titles below.
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...
Duff and Phelps
In this edition: status of the 385 debt regulations in limbo and Australia takes unilateral action by enacting diverted profits tax.
Duff and Phelps
In this edition: 2017 tax reform, important new requirements for Luxembourg finance company tax rulings and ATO hubs practical compliance guide
Duff and Phelps
In this edition: U.S. tax court rules in favor of Amazon, U.S. tax reform and the effects on transfer pricing, OECD releases toolkit for identifying financial data in developing countries...
Duff and Phelps
In this edition: the OECD releases discussion draft on hard-to-value intangibles, Australia issues risk framework for evaluating intercompany loans, recent transfer pricing developments in India, ...
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Duff and Phelps
In this edition: U.S. tax court rules in favor of Amazon, U.S. tax reform and the effects on transfer pricing, OECD releases toolkit for identifying financial data in developing countries...
Duff and Phelps
In this edition: 2017 tax reform, important new requirements for Luxembourg finance company tax rulings and ATO hubs practical compliance guide
McDermott Will & Emery
Our June 2017 blog posts are available on insidesalt.com, or read each article by clicking on the titles below.
Duff and Phelps
In this edition: the OECD releases discussion draft on hard-to-value intangibles, Australia issues risk framework for evaluating intercompany loans, recent transfer pricing developments in India, ...
Dentons
Glenn DeSouza, transfer pricing leader in Dentons' Shanghai office, examines China's transfer pricing regime as outlined in three bulletins, the most recent of which was issued in March.
Duff and Phelps
On January 31, 2017, the IRS announced that its Large Business and International ("LB&I") division will focus on issue-based examinations.
Duff and Phelps
In this edition: status of the 385 debt regulations in limbo and Australia takes unilateral action by enacting diverted profits tax.
Duff and Phelps
The report discloses that 98 complete APA applications were filed with the APMA Program in 2016, indicating a significant decrease from the 183 complete applications filed in 2015.
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.
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