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Searching Content indexed under Transfer Pricing by Shearman & Sterling LLP ordered by Published Date Descending.
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Ninth Circuit Redo In Altera Upholds Treasury Regulation On Stock-Based Compensation
On June 7, 2019, in Altera Corp. v. Commissioner[1], a reconstituted panel of the U.S. Court of Appeals for the Ninth Circuit issued a new opinion upholding the validity of a Treasury Department
United States
3 Jul 2019
2
MIDCO Transactions And The Expanding Universe Of Transferee Liability
The Internal Revenue Service's determination of transferee liability, essentially secondary liability, resulting from transactions involving the taxable sale and disposition of corporate stock...
United States
25 Apr 2016
3
US Banking Agencies Issue Interagency Guidance On Funds Transfer Pricing Related To Funding And Contingent Liquidity Risks
The guidance notes that an institution's FTP framework should be adequately tailored to its size, complexity, business activities and overall risk profile.
United States
30 Mar 2016
4
District Court Grants Evidentiary Hearing In Dispute Over IRS Use Of Private Firm In Microsoft Audit
The saga started in 2007, when the IRS began investigating Microsoft's activities from 2004 to 2006.
United States
9 Sep 2015
5
OECD Moves Forward On BEPS Action Plan
The Organization for Economic Cooperation and Development recently held its annual tax conference in Washington, DC.
United States
23 Jul 2014
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