The Mutual Agreement Procedure ("MAP") is a useful dispute resolution mechanism for multinational companies facing a transfer pricing...
In Through the Looking-Glass, by Lewis Carroll, Humpty Dumpty makes the following point when speaking to Alice
The nexus rules are designed to protect the interests of smaller jurisdictions, and in particular developing economies, and their desire to benefit from the new taxing right.
Akin Gump Strauss Hauer & Feld LLP
During the course of 2020, the U.K. government has pushed ahead with introducing new measures that are likely to be of material relevance to financial
Holland & Knight
Expatriation has increased significantly in 2020. The latest U.S. Department of the Treasury Report reflects that a record 6,047 individuals expatriated during the first three quarters of 2020.
Ostrow Reisin Berk & Abrams
The COVID-19 pandemic has resulted in financial losses for many businesses, including manufacturers.
Wilson Elser Moskowitz Edelman & Dicker LLP
William D. Lipkind (Partner-New Jersey) and Adam Buchwalter (Of Counsel-New Jersey) reported on "Benefits for U.S. Retirement Plan Participants in the Malta-U.S. Tax Treaty."
Reinhart Boerner Van Deuren s.c.
As the end of the year nears, a U.S. subsidiary may try to repatriate cash to its foreign parent. Repatriation may occur in several different methods with each having advantages and disadvantages.
Hodgson Russ LLP
The COVID-19 crisis continues to throw off a variety of tax questions and issues that 60 days ago likely would have been unimaginable.
Congress reacted swiftly to the Tax Court decision holding that no withholding tax should be imposed on the disposition of a partnership interest by a non-US investor in a partnership that was engaged in the conduct of a US trade or business.
Proskauer Rose LLP
On October 7, 2020, the U.S. Internal Revenue Service and Treasury Department released final regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions of certain partnership interests by non-U.S. persons.
Sheppard Mullin Richter & Hampton
Given the pandemic and all that has come along with it, telecommuting has become the new norm. Employers are increasingly faced with difficult legal issues ...
Cadwalader, Wickersham & Taft LLP
On September 21, 2020, the IRS and Treasury Department released final regulations under sections 864(c)(8) and 1446(f) of the tax code. These regulations finalize proposed regulations...
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.
COVID-19 has sparked a seismic change in the workplace as many companies have found that working from home ("WFH") has not diminished employee productivity and that employees prefer its...
Cadwalader, Wickersham & Taft LLP
Following on from the second part in this series, which looked at the proposal under Pillar One, the third and penultimate part in this series will examine the proposal under Pillar Two.
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...
Shearman & Sterling LLP
On July 23, 2020, the U.S. Department of Treasury ("Treasury") and the Internal Revenue Service (IRS) finalized regulations (T.D. 9902) with respect to the global intangible low-taxed income...
The Organisation for Economic Co-Operation and Development and G20 member countries are developing a standardised approach to taxing the digital economy.
Ropes & Gray LLP
Tax partner Kat Gregor and tax counsel Elizabeth Julia Smith published a chapter in the International Comparative Legal Guide – Corporate Tax 2021 entitled...