Searching Content indexed under Transfer Pricing by Andrew Roberson ordered by Published Date Descending.
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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
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
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 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
Altera: Tax Court Invalidates Section 482 Regulation On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
20 Aug 2015
The 3M Case: Can The IRS Overrule The Supreme Court?
In March 2013, 3M filed a petition with the U.S. Tax Court challenging the Internal Revenue Service's determination that $23.6 million in additional royalty income should be allocated to 3M's U.S. headquarters from its Brazilian subsidiary.
United States
27 Sep 2013
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