Mondaq USA: Tax > Transfer Pricing
Rimon P.C.
Incoming European Commission President Ursula van der Leyen has set out as her primary goal moving forward the mission of further unifying Europe and "protecting the European way of life."
Morrison & Foerster LLP
Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon's victory in a major transfer pricing dispute
Ropes & Gray LLP
On August 16, 2019, the Ninth Circuit upheld Amazon's cost-sharing arrangement and valuation of its intangible assets, affirming the Tax Court's 2017 decision
Dickinson Wright PLLC
With the 9th Circuit Court of Appeal's recent decision in Amazon.com Inc. et al v Commissioner of Internal Revenue, upholding a U.S. Tax Court ruling rejecting a broader definition of intangible assets.
Cooley LLP
On August 9, the US Department of the Treasury released proposed regulations on the federal income tax treatment of "cloud transactions"
Mayer Brown
Prior to the Tax Cuts and Jobs Act of 2017 ("TCJA"), the appeal of cost sharing was driven largely by the deferral of U.S. taxation on foreign earnings.
Duff and Phelps
The tax challenges of the digitalization of the economy were identified as a primary area of focus in the 2015 BEPS Action 1 Report.
Duff and Phelps
Review of the applicable guidance for these approaches can assist with taxpayer's own assessment of risk and documentation planning for the current year.
Duff and Phelps
The Medtronic case is slated to head back to court in April of 2020 in accordance with an order from the tax court.
Ruchelman PLLC
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 ง163(j) has focused the attention of U.S. corporations ...
Duff and Phelps
On June 7, 2019 the Ninth Circuit released their decision on the appeal
Duff and Phelps
On April 16, 2019, the Internal Revenue Service Large Business and International division released an overview of three new compliance campaigns, including a captive services providers campaign.
Duff and Phelps
The document is intended to be used as a starting point for tax treaty negotiations between jurisdictions.
Duff and Phelps
On April 10, 2019, the OECD invited interested parties to provide comments on its draft working paper "What is driving tax morale – Public Consultation Document".
Shearman & Sterling LLP
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
Orrick
The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7...
Rabinovich Sokolov Law Group
Are you looking to transfer property in the Philadelphia area? You should be aware that typically, there are both state and local transfer taxes associated with this type of transaction, in addition to recording fees.
Duff and Phelps
The French government estimates that the DST would raise approximately 500 million Euros per year.
Dentons
Globalization has diminished the barriers encountered by multinational businesses.
Duff and Phelps
Below is a high-level timeline summarizing developments associated with Hungary's Advertisement Tax.
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Ropes & Gray LLP
On August 16, 2019, the Ninth Circuit upheld Amazon's cost-sharing arrangement and valuation of its intangible assets, affirming the Tax Court's 2017 decision
Rimon P.C.
Incoming European Commission President Ursula van der Leyen has set out as her primary goal moving forward the mission of further unifying Europe and "protecting the European way of life."
Morrison & Foerster LLP
Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon's victory in a major transfer pricing dispute
Rabinovich Sokolov Law Group
Are you looking to transfer property in the Philadelphia area? You should be aware that typically, there are both state and local transfer taxes associated with this type of transaction, in addition to recording fees.
Mayer Brown
Prior to the Tax Cuts and Jobs Act of 2017 ("TCJA"), the appeal of cost sharing was driven largely by the deferral of U.S. taxation on foreign earnings.
Dickinson Wright PLLC
With the 9th Circuit Court of Appeal's recent decision in Amazon.com Inc. et al v Commissioner of Internal Revenue, upholding a U.S. Tax Court ruling rejecting a broader definition of intangible assets.
Cooley LLP
On August 9, the US Department of the Treasury released proposed regulations on the federal income tax treatment of "cloud transactions"
Duff and Phelps
The tax challenges of the digitalization of the economy were identified as a primary area of focus in the 2015 BEPS Action 1 Report.
Duff and Phelps
The proposed regulations also provide partial relief by providing exempt income and exempt asset treatment with respect to GILTI income.
Ruchelman PLLC
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 ง163(j) has focused the attention of U.S. corporations ...
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