Mondaq USA: Tax > Transfer Pricing
McLane Middleton, Professional Association
The Tax Cuts and Jobs Act of 2017 can mean good news for folks standing to inherit property.
Duff and Phelps
In this edition: the IRS and Treasury filed a proposal to remove the regulations under Section 1.385-2; Treasury and the IRS issued proposed regulations under Section 951A of the Internal Revenue Code
Duff and Phelps
In this edition: the U.S. Court of Appeals for the Eighth Circuit remands the Medtronic case back to the Tax Court ...
Ruchelman PLLC
The lack of consensus amongst O.E.C.D. Member States on the Discussion Draft may foreshadow difficult double-tax cases between competent authorities.
Womble Bond Dickinson
The public perception is well-established now that international rules are unfit when it comes to taxing digital companies such as Amazon
Morgan Lewis
July 24, 2018, marked a significant, although potentially short-lived, victory for the IRS, as a panel of the US Court of Appeals for the Ninth Circuit reversed by 2 votes to 1, the full US Tax Court's unanimous opinion...
Ropes & Gray LLP
As a result, the Tax Court held that the regulation did not meet the reasoned decision-making standard in the State Farm Supreme Court case.
Morgan Lewis
Serving as a roadmap for how the Internal Revenue Service intends to conduct transfer pricing examinations, the recently released Transfer Pricing Examination Process ...
Ruchelman PLLC
The arrival of an information document request ("I.D.R.") for transfer pricing documentation often comes as a surprise to a company.
Duff and Phelps
The Notice clarifies several important aspects of the amendment, some of which are highlighted below.
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").
Duff and Phelps
On July 3, 2018, the Organisation of Economic Co-operation and Development ("OECD") released the first public discussion draft on the transfer pricing of financial transactions.
Duff and Phelps
On June 21, 2018, the OECD released long-awaited final guidance on the appropriate application of the Transactional Profit Split Method and on Implementing the OECD's guidance on Hard to Value Intangibles.
Duff and Phelps
In this edition: The OECD has invited public comments on scoping the future revision of Chapter IV and Chapter VII of the Transfer Pricing Guidelines; the IRS and Coca-Cola Company ...
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.
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Duff and Phelps
In this edition: the U.S. Court of Appeals for the Eighth Circuit remands the Medtronic case back to the Tax Court ...
Duff and Phelps
In this edition: the IRS and Treasury filed a proposal to remove the regulations under Section 1.385-2; Treasury and the IRS issued proposed regulations under Section 951A of the Internal Revenue Code
McLane Middleton, Professional Association
The Tax Cuts and Jobs Act of 2017 can mean good news for folks standing to inherit property.
Ruchelman PLLC
The lack of consensus amongst O.E.C.D. Member States on the Discussion Draft may foreshadow difficult double-tax cases between competent authorities.
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
By certain measures, December 21 and December 23 were comparable days for the arm's length standard.
Duff and Phelps
On July 3, 2018, the Organisation of Economic Co-operation and Development ("OECD") released the first public discussion draft on the transfer pricing of financial transactions.
Duff and Phelps
In this edition: The OECD has invited public comments on scoping the future revision of Chapter IV and Chapter VII of the Transfer Pricing Guidelines; the IRS and Coca-Cola Company ...
Morgan Lewis
July 24, 2018, marked a significant, although potentially short-lived, victory for the IRS, as a panel of the US Court of Appeals for the Ninth Circuit reversed by 2 votes to 1, the full US Tax Court's unanimous opinion...
Ropes & Gray LLP
As a result, the Tax Court held that the regulation did not meet the reasoned decision-making standard in the State Farm Supreme Court case.
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