Mondaq USA: Tax > Transfer Pricing
Womble Bond Dickinson
With the release January 29, 2019 of an important tax policy note (the "Note"), the OECD has introduced greater direction for its BEPS mandate to introduce proposals to address the tax challenges of the "digitalization" of the economy.
Mayer Brown
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.
Duff and Phelps
On November 26, 2018 the U.S. Department of Treasury and the IRS released proposed regulations that provide guidance on the limitation on the business interest expense deduction for certain taxpayers.
Duff and Phelps
The enactment of H.R. 1, formerly known as the Tax Cuts and Jobs Act ("TCJA"), on December 22, 2017 marks the first major overhaul of the U.S. federal income tax system in over 30 years.
Ruchelman PLLC
Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations: (i) the reduction of European taxes ...
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.
Duff and Phelps
The proposed regulations also provide partial relief by providing exempt income and exempt asset treatment with respect to GILTI income.
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.
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Duff and Phelps
The proposed regulations also provide partial relief by providing exempt income and exempt asset treatment with respect to GILTI income.
Womble Bond Dickinson
With the release January 29, 2019 of an important tax policy note (the "Note"), the OECD has introduced greater direction for its BEPS mandate to introduce proposals to address the tax challenges of the "digitalization" of the economy.
Duff and Phelps
On November 26, 2018 the U.S. Department of Treasury and the IRS released proposed regulations that provide guidance on the limitation on the business interest expense deduction for certain taxpayers.
Duff and Phelps
The enactment of H.R. 1, formerly known as the Tax Cuts and Jobs Act ("TCJA"), on December 22, 2017 marks the first major overhaul of the U.S. federal income tax system in over 30 years.
Mayer Brown
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.
Ruchelman PLLC
Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations: (i) the reduction of European taxes ...
Ruchelman PLLC
By certain measures, December 21 and December 23 were comparable days for the arm's length standard.
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
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
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 ...
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