Mondaq USA: Tax > Transfer Pricing
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.
McDermott Will & Emery
Facebook is in a protracted battle with the IRS related to its off-shoring of IP to an Irish affiliate. The IRS issued an administrative summons for the documents, and Facebook has refused to comply.
Proskauer Rose LLP
The IRS adopted final regulations that no longer require taxpayers who have made Internal Revenue Code §83(b) elections to attach a copy of the election to their annual federal income tax return.
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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.
Jones Day
Medtronic Inc. & Consolidated Subsidiaries v. Commissioner (T.C. Memo. 2016-112) is the latest defeat for the U.S. Internal Revenue Service ("IRS") in a string of transfer pricing losses.
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...
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
One group of six professors first notes its agreement with the arguments advanced by the government in its opening brief.
McDermott Will & Emery
Facebook is in a protracted battle with the IRS related to its off-shoring of IP to an Irish affiliate. The IRS issued an administrative summons for the documents, and Facebook has refused to comply.
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.
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...
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