Searching Content indexed under Transfer Pricing by Ruchelman PLLC ordered by Published Date Descending.
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Debt Characterization And Deductibility Under Domesticated International Rules
The limitation of interest deductibility to approximately 30% of E.B.I.T.D.A. (earnings before interest, tax, depreciation, and amortization) introduced in amended Code §163(j) has focused the attention of U.S. corporations ...
United States
9 Jul 2019
Can Tax Authorities Demand Access To Audit Workpapers? Canadian Experience Follows U.S. Rule
When a Canadian or U.S.-based multinational finds itself under audit, the taxpayer and the tax authority are often at odds over what documentation is subject to disclosure...
United States
8 Mar 2019
Holding Companies Of Europe – Tax Planning For European Expansion In A Changing Landscape
Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations: (i) the reduction of European taxes ...
United States
15 Jan 2019
O.E.C.D. Discussion Draft On Financial Transactions – A Listing Of Sins, Little Practical Guidance
The lack of consensus amongst O.E.C.D. Member States on the Discussion Draft may foreshadow difficult double-tax cases between competent authorities.
United States
18 Oct 2018
Managing A Transfer Pricing Exam? Wash Your Hands With Soap And Water
The arrival of an information document request ("I.D.R.") for transfer pricing documentation often comes as a surprise to a company.
United States
28 Jun 2018
Can The Arm's Length Standard Beat The R.A.P.? Transfer Pricing After The T.C.J.A.
By certain measures, December 21 and December 23 were comparable days for the arm's length standard.
United States
16 Apr 2018
Income Shifting: Common Ownership Or Control Under Code §482 In An Inbound Transaction
The Large Business and International Division of the I.R.S. ("LB&I") periodically develops international practice units ("I.P.U.'s") that serve as training material ...
United States
6 Feb 2018
Tax Cuts And Jobs Act Adopt Provisions To Prevent Base Erosion
Following the lead of the O.E.C.D. and the European Commission ("E.C."), the Tax Cuts and Jobs Act ("T.C.J.A.") adopts several provisions designed to end certain tax planning opportunities.
United States
5 Feb 2018
The Sharing Economy Part 1:New Business Models +Traditional Tax Rules Don't Mix
The current international tax system was established on principles dating back to the first half of the 19th century, when the internet did not exist and the economy mostly consisted of brick-and-mortar stores.
United States
17 Nov 2017
Eaton A.P.A. Cancellations Were An Abuse Of I.R.S. Discretion
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...
United States
5 Oct 2017
Bilateral Investment Treaties: When Double Taxation Agreements Are Not Enough
The U.S. enters into bilateral investment treaties ("B.I.T.'s") to protect and promote foreign investment.
United States
3 Oct 2017
Deemed Annual Royalty On Outbound Transfers Of I.P. To Foreign Corporations
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.
United States
2 Oct 2017
I.R.S. Identifies Regulations Imposing Undue Burden On Taxpayers
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").
United States
4 Sep 2017
Amazon Makes The C.U.T. – An Important Taxpayer Win, A Reminder To Consider Transactional Evidence
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...
United States
14 Jun 2017
Tax Concerns On Outbound I.P. Transfers: Pitfalls & Planning
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...
United States
10 May 2017
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