Mondaq USA: Tax > Transfer Pricing
McDermott Will & Emery
The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on federal tax reform.
Ruchelman PLLC
As the transfer pricing travails of Eaton Corporation ("Eaton") continue, a recent U.S. Tax Court decision affirmed that (i) I.R.S. administrative rules set down in rev¬enue procedures...
Ruchelman PLLC
The U.S. enters into bilateral investment treaties ("B.I.T.'s") to protect and promote foreign investment.
Proskauer Rose LLP
Yesterday, the Trump Administration, the House Committee on Ways and Means, and the Senate Finance Committee proposed a "unified framework" for tax reform.
Ruchelman PLLC
For many years, the U.S. government has been concerned about U.S. businesses reducing or deferring U.S. income tax liabilities through the use of foreign corporations.
Ruchelman PLLC
On April 21, 2017, President Trump issued Executive Order 13789 (the "Order") with the objective of identifying and reducing tax regulatory burdens imposed by Treasury Regulations (the "Regulations").
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.
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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Ruchelman PLLC
The U.S. enters into bilateral investment treaties ("B.I.T.'s") to protect and promote foreign investment.
McDermott Will & Emery
The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on federal tax reform.
Ruchelman PLLC
For many years, the U.S. government has been concerned about U.S. businesses reducing or deferring U.S. income tax liabilities through the use of foreign corporations.
Ruchelman PLLC
As the transfer pricing travails of Eaton Corporation ("Eaton") continue, a recent U.S. Tax Court decision affirmed that (i) I.R.S. administrative rules set down in rev¬enue procedures...
Proskauer Rose LLP
Yesterday, the Trump Administration, the House Committee on Ways and Means, and the Senate Finance Committee proposed a "unified framework" for tax reform.
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...
Duff and Phelps
In this edition: 2017 tax reform, important new requirements for Luxembourg finance company tax rulings and ATO hubs practical compliance guide
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.
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...
Ruchelman PLLC
On April 21, 2017, President Trump issued Executive Order 13789 (the "Order") with the objective of identifying and reducing tax regulatory burdens imposed by Treasury Regulations (the "Regulations").
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