Searching Content indexed under Transfer Pricing by Morrison & Foerster LLP ordered by Published Date Descending.
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Amazon Prevails In Ninth Circuit – Government Opportunism Rejected
Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon's victory in a major transfer pricing dispute
United States
23 Sep 2019
IRS Issues Notice Announcing Intention To Require Gain Recognition On Certain Transfers Of Property To Partnerships With Related Foreign Partners
On August 6, 2015, the IRS and the Treasury Department announced their intention in Notice 2015-54 to issue regulations under Sections 721(c), 482, and 6662 of the Internal Revenue Code.
United States
21 Sep 2015
Ninth Circuit Issues Opinion in Key Transfer Pricing Case: Arm's Length Standard Vindicated
On March 22, the Ninth Circuit issued its opinion affirming the opinion of the United States Tax Court in Xilinx, Inc. v. Commissioner.
United States
4 Apr 2010
Outsourcing and Tax - August 2007
This article covers two subjects. Firstly, it addresses the complex tax issues that can arise on an outsourcing project. And, secondly but no less importantly, it explains the connection between tax, outsourcing and Attila the Hun.
9 Aug 2007
SAFE Circular 75 - The Key Provisions of Circular 75 and What They May Mean for Investors
The dust is beginning to settle on the effect and fate of SAFE Circular 11 and Circular 29, at least for the time being. On October 21, 2005, SAFE issued the long awaited new circular on "Relevant Issues Concerning Foreign Exchange Control on Domestic Residents' Corporate Financing and Roundtrip Investment Through Offshore Special Purpose Vehicles"
United States
9 Nov 2005
Communications Law Bulletin -- October 2005
October brought several important developments in the telecommunications world, including final approval by the Department of Justice and Federal Trade Commission of mergers involving the four largest local and long-distance telephone companies in the United States. The FCC also responded to the aftermath of Hurricane Katrina, and fallout continued from the Commission’s Triennial Review Remand Order. These and other events are covered here, along with our usual list of deadlines for your calenda
United States
4 Nov 2005
Deferred Compensation Update: IRS Issues Proposed Regulations under Code Section 409A
On September 29, 2005, the IRS issued its long-awaited proposed regulations under Code Section 409A (the "Proposed Regulations").
United States
27 Oct 2005
China M&A Newsletter - September 2005
The past twenty-four months have seen a surge in the number of increasingly sophisticated merger and acquisition transactions involving U.S., Japanese and European multinationals and China-based companies (listed and unlisted, private and state-owned). Morrison & Foerster has advised on many such transactions, including representing Softbank in connection with Yahoo!’s US$1 billion investment in Softbank’s China affiliates, and Tao Bao; UPS in its acquisition of its international exp
29 Sep 2005
China Law Bulletin - July 2005
In this issue: Foreign Direct Investment; Foreign Exchange Administration; Intellectual Property Rights; Labor Law; Retailing/Distribution; Securities; State-owned Enterprises; Draft Legislation
28 Jul 2005
The New Technology Transfer Block Exemption
The new Technology Transfer Block Exemption ("the TTBE"), which entered into force on May 1, presents the final step in the Commission’s program to overhaul Article 81 EC. Compared to its predecessor, generally referred to as "the last dinosaur," the TTBE introduces a considerable degree of flexibility into the framework underlying the competition law analysis of technology licensing agreements.
United States
8 Jun 2004
New York City Tribunal Decision in Toys "R" Us-NYTEX Confirms Arm’s Length Pricing As Key to Combination
The New York City Tax Appeals Tribunal recently issued what may be the most significant taxpayer victory in New York to date on when the New York tax authorities may forcibly combine a corporate taxpayer with an affiliated intangibles holding company.
United States
27 Apr 2004
New Rules 38a-1 and 206(4)-7 for Investment Companies and Advisers
Newly adopted rules will require each investment company and investment adviser registered with the Commission to implement policies and procedures designed to prevent violation of the federal securities laws, and designate a chief compliance officer "CCO" to administer them. The policies and procedures and CCO must be in place by October 5, 2004.
United States
22 Jan 2004
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