Searching Content indexed under Transfer Pricing by Mayer Brown ordered by Published Date Descending.
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Applying Acquisition Price Method To Post-TCJA Platform Contribution Transactions
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.
United States
13 Aug 2019
IRS Issues Proposed Regulations Implementing Base Erosion Anti-Abuse Tax (BEAT) Rules
On December 13, 2018, the US Internal Revenue Service released an initial set of proposed regulations addressing a number of open issues under the Base Erosion Anti-Abuse Tax (BEAT) rules.
United States
28 Jan 2019
OECD Releases Country-By-Country Reporting Implementation Package; US Implementation Unclear
The Organisation for Economic Co-operation and Development has released its "Country-by-Country Reporting Implementation Package".
United States
16 Jun 2015
Significant Progress Made On The OECD’s BEPS Action Plan
This Legal Update is the second in a series that Mayer Brown Tax lawyers are publishing on key developments at the national and international levels related to the Organisation for Economic Co-Operation and Development’s ("OECD") Action Plan on Base Erosion and Profit Shifting (the "BEPS Action Plan").
10 Mar 2014
The OECD’s Action Plan On Base Erosion And Profit Shifting
The Organisation for EconomicCoordination and Development released its highly anticipated Action Plan on Base Erosion and Profit Shifting, which was then unanimously approved by the G-20 Finance Ministers at their July 20, 2013 meeting in Moscow.
United States
1 Aug 2013
Year-End Estate Planning Strategies for Today’s Economic Times
Many have referred to this period as a "perfect storm" for estate planning. That is due to the generally low value of many assets, low interest rates, the historically low gift tax rate and the repeal of the generation-skipping transfer tax (GST).
United States
25 Oct 2010
German Law Finally Comes To Terms With Most Favored Customer Clauses
In outsourcing agreements, customers typically request a so-called "Most Favored Customer" or "Most Favored Nation" clause from their service provider.
United States
27 Oct 2005
Key Issues In Outsourcing: A Supplier’s Perspective
In most, if not all, outsourcing transactions, suppliers find themselves in a competitive environment. This environment often involves the issuance by a prospective customer to several suppliers of a request for proposal that likely contains business and legal terms and conditions and requires suppliers to indicate their willingness to accept them.
United States
12 Oct 2005
Legal Problems Arising in the Course of the Transfer of Credit Portfolios Can be Solved
Although many legal aspects have to be observed within the course of the sale of distressed loans, there are no legal obstacles in Germany which would bar such sales.
22 Jun 2005
Foreign Investment in India
The legal, economic and financial reforms undertaken by the Indian government since the early 1990’s have resulted in substantial and rapid growth of the Indian economy and led to the integration of India into the global economy. While reform efforts stalled somewhat during the weak coalition governments of the mid-1990’s, following the 1999 parliamentary elections, the Bharatiya Janata Party-led government launched a second round of economic reforms, which included major privatization, deregula
United States
26 May 2005
"Extraordinary Events" in an Outsourcing Relationship: Managing Acquisitons and Divestures
One of the keys to a successful outsourcing relationship is flexibility—in the contract terms and in the relationship. Flexibility is required to meet ever-changing business needs through the life of the deal. This flexibility is put to the test when a customer experiences an "extraordinary event" such as a merger, acquisition or divestiture.
United States
10 Jun 2004
The Draft Block Exemption Regulation on Technology Transfer Agreements – Is the New Safe Harbor Less Safe?
On 1 October 2003, the European Commission published its draft block exemption Regulation on the application of Article 81(3) EC Treaty to technology transfer agreements1 ("Draft TTBER").
17 May 2004
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