Mondaq USA: Tax > Transfer Pricing
Eisner Amper
It has been over a year since the Tax Cuts and Jobs Act was enacted. The transfer pricing rules set forth in the treasury regulations with respect to IRC Sec. 482 have remained relatively unchanged since 1986.
Duff and Phelps
The French government estimates that the DST would raise approximately 500 million Euros per year.
Dentons
Globalization has diminished the barriers encountered by multinational businesses.
Duff and Phelps
The IRS is requesting that the Court of Appeals for the Ninth Circuit remand the U.S. Tax Court's decision.
Duff and Phelps
The BEAT is in addition to the taxpayer's regular tax liability.
Akin Gump Strauss Hauer & Feld LLP
The Organisation for Economic Co-operation and Development (OECD) will kick off tomorrow a public consultation on its most recent foray into the tax challenges arising from the digitalization
Ruchelman PLLC
When a Canadian or U.S.-based multinational finds itself under audit, the taxpayer and the tax authority are often at odds over what documentation is subject to disclosure...
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.
Duff and Phelps
It is Duff & Phelps' understanding that the OECD's draft is also in the process of being finalized and will likely be made available this year.
Duff and Phelps
On March 1, 2019, the APMA program announced the introduction of a new Excel-based model which taxpayers that are seeking an APA may be required to complete as part of the APA process.
Duff and Phelps
In this edition: The OECD unveiled the latest proposals to address the tax challenges of the digitalization of the economy; the IRS updated its tax statistics database with Statistic of Income data for tax year 2016;
Duff and Phelps
The proposed regulations also provide partial relief by providing exempt income and exempt asset treatment with respect to GILTI income.
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Duff and Phelps
The BEAT is in addition to the taxpayer's regular tax liability.
Eisner Amper
It has been over a year since the Tax Cuts and Jobs Act was enacted. The transfer pricing rules set forth in the treasury regulations with respect to IRC Sec. 482 have remained relatively unchanged since 1986.
Dentons
Globalization has diminished the barriers encountered by multinational businesses.
Duff and Phelps
The IRS is requesting that the Court of Appeals for the Ninth Circuit remand the U.S. Tax Court's decision.
Duff and Phelps
It is Duff & Phelps' understanding that the OECD's draft is also in the process of being finalized and will likely be made available this year.
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
The French government estimates that the DST would raise approximately 500 million Euros per year.
Duff and Phelps
In this edition: The OECD unveiled the latest proposals to address the tax challenges of the digitalization of the economy; the IRS updated its tax statistics database with Statistic of Income data for tax year 2016;
Duff and Phelps
On March 1, 2019, the APMA program announced the introduction of a new Excel-based model which taxpayers that are seeking an APA may be required to complete as part of the APA process.
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 ...
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