The Development: The EU General Court annulled the European Commission's decision in the Apple case, holding that the Commission did not prove that the Irish tax rulings in question...
Cadwalader, Wickersham & Taft LLP
On September 29, 2020, Treasury and the IRS issued final regulations on how to source gain from inventory sales
Chilean tax authorities recently adopted a three-tiered approach to transfer pricing documentation. Chile is one of the few Latin American countries...
Earlier this year, the I.R.S. updated its Transfer Pricing Documentation Best Practices F.A.Q. list with a response to Q. 4, What are some areas the I.R.S. has identified in transfer pricing...
Fundraising: Accessing US Venture Capital.
Multinational organisations have been operating during a pandemic for six months now. Over that span many employers have increasingly ...
Caplin & Drysdale
Taxpayers with cost sharing arrangements ("CSAs") can again expect close audit scrutiny—and potential adjustments—related to their treatment of stock-based compensation ("SBC") costs.
Caplin & Drysdale
On August 1, 2020, North Carolina announced its first formal voluntary disclosure initiative aimed specifically at resolving corporate transfer pricing liabilities.
Proskauer Rose LLP
In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers' argument that a notice of a tax claim under a tax covenant served on them by the buyer ...
The E.U. Council Directive 2018/822 ("DAC6") provides for the mandatory disclosure by intermediaries, or individual or corporate taxpayers, to H.M.R.C.
The US Internal Revenue Service (IRS) is auditing a large multinational company. One issue that has emerged is the company's "transfer pricing," the pricing of goods, services, ...
Reinhart Boerner Van Deuren s.c.
Are you documenting all your intercompany transactions? If your transactions with a foreign affiliate exceed $10 million, your U.S. company is in danger of an IRS transfer pricing adjustment and a penalty.
It is possible that Blondie was speaking from the perspective of the IRS in its hit song "One Way or Another"...
Holland & Knight
A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation.
Pearl Cohen Zedek Latzer Baratz
On the flip side, when the group earns significant profits, the low-risk entity will continue to record the same limited profit margin.
The O.E.C.D. announced on January 31, 2020, that its policy development efforts under Pillar One, related to the taxation of the digital economy, will move forward using the non-consensus...
Buchanan Ingersoll & Rooney PC
Virus Upends Tax Planning for Companies Facing Sudden Losses.
During a 2019 Tax Executives Institute conference in Washington, D.C., the Commissioner of the U.S. Internal Revenue Service (IRS), ...
On February 18, 2020, EU finance ministers updated the EU Blacklist, adding four jurisdictions—the Cayman Islands, Palau, Panama and Seychelles.
Driven by ever-advancing technologies, today's multinationals need to quickly adapt to new ways of doing business — a process that can often leave them more vulnerable to risk including tax and transfer pricing, ...