Mondaq USA: Tax > Transfer Pricing
Ruchelman PLLC
By certain measures, December 21 and December 23 were comparable days for the arm's length standard.
Duff and Phelps
On December 22, 2017, President Donald Trump signed the Tax Cuts and Jobs Act (the "Act") which introduced sweeping changes to the U.S. tax code.
Ruchelman PLLC
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 ...
Ruchelman PLLC
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.
Stroock & Stroock & Lavan LLP
On December 2, 2017, in the early hours of Saturday morning, the U.S. Senate passed its version of the comprehensive tax reform bill (the "Senate bill").
Proskauer Rose LLP
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10.
Ruchelman PLLC
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.
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.
Duff and Phelps
On March 16, 2018, the OECD/G20 Inclusive Framework on BEPS issued its Interim Report on the Tax Challenges Arising from Digitalization.
Duff and Phelps
On January 12, 2018, the U.S. IRS Large Business and International ("LB&I") Division issued several new directives establishing procedural changes aimed at enabling the IRS to manage resources in transfer pricing audits.
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
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Duff and Phelps
On March 16, 2018, the OECD/G20 Inclusive Framework on BEPS issued its Interim Report on the Tax Challenges Arising from Digitalization.
Ruchelman PLLC
By certain measures, December 21 and December 23 were comparable days for the arm's length standard.
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
On December 22, 2017, President Donald Trump signed the Tax Cuts and Jobs Act (the "Act") which introduced sweeping changes to the U.S. tax code.
Ruchelman PLLC
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.
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
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.
Duff and Phelps
On January 12, 2018, the U.S. IRS Large Business and International ("LB&I") Division issued several new directives establishing procedural changes aimed at enabling the IRS to manage resources in transfer pricing audits.
Ruchelman PLLC
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 ...
Duff and Phelps
In this edition: 2017 tax reform, important new requirements for Luxembourg finance company tax rulings and ATO hubs practical compliance guide
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