Searching Content indexed under Transfer Pricing by McDermott Will & Emery ordered by Published Date Descending.
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State And Local Tax Aspects Of Republican Tax Reform Framework
The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on federal tax reform.
United States
6 Oct 2017
Finishing SALT: Inside SALT's Monthly Recap
Our June 2017 blog posts are available on, or read each article by clicking on the titles below.
United States
20 Jul 2017
UTP Filings Continue To Rise
The IRS has released statistics for the 2010 to 2014 tax years relating to Schedule UTP filings, showing that there were 6,320 uncertain tax positions reported in 2014.
United States
18 Oct 2016
Altera Corporation Files Answering Brief In Commissioner's Ninth Circuit Appeal Of Altera
In Altera Corp v Commissioner, 145 TC No. 3, the Tax Court, in a unanimous reviewed opinion, held that regulations under Section 482 requiring parties to a QCSA to include stock-based compensation...
United States
21 Sep 2016
Brexit: The Consequences For International Tax Planning
Just over a month has now passed since the Brexit referendum, an event which some have characterized as the greatest potential shock to the UK economy since the Second World War.
17 Aug 2016
Introduction To The New World Of Global Tax Planning
As all multinationals are discovering, domestic implementation of the recommendations set out in the BEPS final reports from 2015 have the potential to significantly impact effective tax rate planning.
United States
17 Aug 2016
Inversions And Debt/Equity Regulations Top Treasury's 2016–2017 Priority Guidance Plan
The public is invited to continue to provide comments and suggestions as guidance is written throughout the year.
United States
17 Aug 2016
Facebook Battles IRS In Summons Enforcement Case
Facebook is in a protracted battle with the IRS related to its off-shoring of IP to an Irish affiliate. The IRS issued an administrative summons for the documents, and Facebook has refused to comply.
United States
15 Aug 2016
Treasury To Publish Proposed Regulations Regarding Valuing Interests In Corporations And Partnerships For Gift And Estate Tax Purposes
The IRS has just proposed regulations regarding the valuation of interests in corporations and partnerships for federal transfer tax purposes.
United States
10 Aug 2016
Law School Professors File Amicus Briefs In Support Of Commissioner's Position In Altera
One group of six professors first notes its agreement with the arguments advanced by the government in its opening brief.
United States
5 Aug 2016
IRS Issues IPU On Corporate Inversions
On June 7, 2016 , the IRS released an LB&I International Practice Unit, providing high-level guidance to IRS field examiners on the application of the anti-inversion rules of Internal Revenue Code section 7874.
United States
7 Jul 2016
IRS Wages ‘Campaigns' against Taxpayers
Late last year, the Internal Revenue Service's (IRS's) Large Business and International (LB&I) division announced that it would restructure its organization.
United States
29 Jun 2016
IRS Publishes Another IPU On Transfer Pricing
The Internal Revenue Service (IRS) continues to publish International Practice Units (IPUs) on transfer pricing.
United States
8 Jun 2016
ABA Seeks Priority Guidance For Transfer Pricing Issues
While the IRS does not explicitly mention goodwill or going concern the regulations are intended to sweep in the consideration of any goodwill, including synergy, value that may relate to such transactions.
United States
8 Jun 2016
Two Current Tax Controversies Utilize ‘Quick Peek' Agreements To Resolve Privilege Disputes
Due to the enormous amount of electronic data stored by companies in the modern era, discovery requests can involve millions of documents which need to be reviewed prior to being turned over to the opposing party.
United States
1 Jun 2016
Should I Register In South Dakota?
On March 22, 2016, South Dakota Governor Dennis Daugaard signed into law Senate Bill 106, which requires any person making more than $100,000 of South Dakota sales or more than 200 separate South Dakota sales transactions to collect and remit sales tax.
United States
22 Apr 2016
MTC Arm's-Length Adjustment Service (Part II): "An Expression Of Grief, Pity, Or Concern"
The inaugural meeting (via conference call) of the Multistate Tax Commission's Committee (Committee) addressing transfer pricing issues (ALAS) took place on April 7, 2016, and was certainly interesting.
United States
12 Apr 2016
International Tax Disputes: A Ray Of Hope
Despite the anticipated tsunami of tax disputes generated by underlying tensions in international taxation, there is reason for hope that appropriate means are being developed to address them efficiently and effectively.
United States
29 Jan 2016
Tax Court Decision In Altera Overturns Important Transfer Pricing Regulations
On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services' (IRS) cost-sharing regulations under section 482 of the Internal Revenue Code that says taxpayers have to take into account, among other costs, the costs of stock-based compensation.
United States
5 Oct 2015
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